• 31 Days to a More Effective Compliance Program

  • By: Thomas Fox
  • Podcast

31 Days to a More Effective Compliance Program

By: Thomas Fox
  • Summary

  • Tom Fox is the Compliance Evangelist and is universally recognized as one of the top experts in corruption compliance, literally across the globe. In this daily podcast series, he explains how to design, create and implement a best practices compliance program. Each month, he tackles a different area of compliance. From Internal Controls, to the Role of the Board of Directors, to Communication, to the Role of HR in Compliance, Investigations, 3rd Parties and Business Ventures. Listen in each day and get one tip you can implement at little or no cost to enhance your compliance program.
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Episodes
  • 31 Days to a More Effective Compliance Program: Day 31 - Using a Root Cause Analysis for Remediation
    Jan 31 2024
    The 2023 ECCP re-emphasized the need for both performing a root cause analysis but equally importantly using it to remediate your compliance program. It stated, “a hallmark of a compliance program that is working effectively in practice is the extent to which a company is able to conduct a thoughtful root cause analysis of misconduct and timely and appropriately remediate to address the root causes.” It went on to state, what additional steps the company has taken “that demonstrate recognition of the seriousness of the misconduct, acceptance of responsibility for it, and the implementation of measures to reduce the risk of repetition of such misconduct, including measures to identify future risk.”  When you step back and consider what the DOJ was trying to accomplish with its 2023 ECCP, it becomes clear what the DOJ expects from the compliance professional. Consider the structure of your compliance program and how it inter-relates to your company’s risk profile. When you have a compliance failure, use the root cause analysis to think about how each of the structural elements of your compliance program could impact how you manage and deal with that risk.  Three key takeaways: 1. The key to using a root cause analysis is objectivity and independence. 2. The critical element is how did you use the information you developed in the root cause analysis? 3. The key is that after you have identified the causes of problems, consider the solutions that can be implemented by developing a logical approach, using data that already exists in the organization. Learn more about your ad choices. Visit megaphone.fm/adchoices
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    8 mins
  • 31 Days to a More Effective Compliance Program: Day 30 - The Foreign Extortion Prevention Act
    Jan 30 2024
    The compliance community has long recognized the gaping hole in the FCPA. As a supply-side law, it criminalizes the payment of bribes, not the demand to pay a bribe or extortion. The gap was recently filled by the Foreign Extortion Prevention Act (FEPA), which extended crucial protections to Americans working abroad and provided the DOJ with a potent new tool. By criminalizing both the giving and demanding of foreign bribes, FEPA seeks to level the playing field for American workers while fostering ethical business practices globally. FEPA represents a promising solution to protect Americans working overseas, promote fair business competition, and combat corruption on a global scale. With its potential to bring about meaningful change, FEPA is a vital step in safeguarding American values and interests in the international arena. Sam Rubenfeld, cited Scott Greytak, the director of advocacy for Transparency International US, for the following: “FEPA is a landmark, bipartisan law that holds the potential to help root out foreign corruption at its source. It is arguably the most sweeping and consequential foreign bribery law in nearly half a century.” Three key takeaways: 1. FEPA changes the game for ABC. 2. Make sure your policies and procedures capture any extortion attempts made illegal under FEPA. 3. Determine your external reporting for FEPA violations. For more information on Ethico and a free White Paper on top compliance issues in 2024, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices
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    8 mins
  • 31 Days to a More Effective Compliance Program: Day 29 -Strategic Considerations for Implementing AI in Compliance
    Jan 29 2024
    Implementing AI in compliance requires strategic considerations and decision-making. Understanding the impact of AI, maintaining an inventory of tools, considering cost efficiency and risk avoidance, involving all business sectors, and utilizing AI for better data usage are key factors to consider. Balancing exploration and rules, as well as selecting the right AI tools, are challenges that need to be addressed. By carefully navigating these considerations and challenges, companies can leverage AI to enhance their compliance programs and stay ahead in an ever-evolving regulatory landscape.  Three key takeaways:  1. What are the key factors that impact these strategic considerations for implementing AI in compliance? 2. Compliance professionals need to stay updated with the latest AI developments and trends, which requires continuous learning and keeping abreast of industry news and insights. 3. Understanding the impact of AI, maintaining an inventory of tools, considering cost efficiency and risk avoidance, involving all business sectors, and utilizing AI for better data usage are key factors to consider. For more information on Ethico and a free White Paper on top compliance issues in 2024, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices
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    8 mins

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