Sentencing Commission Confidential – Sentencing Data on Organizations

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There’s not a lot of data out there to tell us how the Department of Justice or other regulators view compliance initiatives, or what expectations really are. We know what the guidance tells us, but what happens in the real world when a company’s compliance program is looked at? We can get some indications from…

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Sentencing Commission Confidential – Personnel

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For this episode Eric dives into the commonly conflated terms “substantial authority personnel” and “high-level personnel” that are defined in the Sentencing Guideline standards for an effective compliance and ethics program. Knowing which is which, and what the expectations are for a compliance program, is very important and not often discussed. Also, check out our…

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2019 SCCE Compliance and Ethics Institute Preview

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Eric spends a few minutes looking back at CEI’s past — and talking about the threads and new trends in this year’s event. If you are visiting DC this week then come by and see Eric at Booth 106. If not, we hope to see you next time! https://www.corporatecompliance.org/conferences/national/18th-annual-compliance-ethics-institute-2019 “SCCE’s annual Compliance & Ethics Institute…

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Privacy Bulletin: A Discussion on Privacy Compliance with Teresa Troester-Falk (PART II)

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This time Eric is Teresa Troester-Falk to discuss the pending new privacy law from California, potential new laws in several states, and how it relates to GDPR and privacy compliance generally. This is the Second part of a two part conversation. If you haven’t listened to Part I we encourage you to do so. Teresa…

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Privacy Bulletin: A Discussion on the California Consumer Privacy Act and Privacy Compliance with Teresa Troester-Falk (PART I)

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This time Eric is Teresa Troester-Falk to discuss the pending new privacy law from California and how it relates to GDPR and privacy compliance generally. This is the first part of a two part conversation. Join us next week for part two. Teresa is Chief Global Strategist for Nymity where she leads some of Nymity’s…

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Sentencing Commission Confidential: Who Speaks To The Board?

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This time, in anticipation for a Sentencing Guideline presentation next month at the SCCE’s CEI in Washington DC, we have another belated edition of Sentencing Commission Confidential. Eric talks about a commonly overlooked or misunderstood part of Chapter Eight of the guidelines that sets out responsibilities for reporting to the Board (or governing authority) of…

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Three Key Components for Compliance Surveys

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These days it’s easy to find and use survey tools. While the tools have become more accessible and powerful, there are some steps you are going to want to carefully consider to produce the best results. Eric discusses three areas that he believes can help you design and deliver a more efficient and successful survey…

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Three Key Components for a Compliance Program Assessment

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This time Eric discusses compliance program assessments – or risk assessments – or program benchmarking – or whatever you want to call the periodic review of your program that the Sentencing Guidelines, USDOJ guidance and best practices call for. Eric discusses three key pieces of the puzzle you might want to consider whether you are…

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Do We Need Compliance Expertise on the Board?

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One of the questions raised by the recent updated USDOJ guidance is the question of “expertise” at or on the board of directors. Eric takes some time this week to discuss the guidance and the practical considerations about expertise in the boardroom. If you are interested in the intersection of compliance and the board of…

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3 Tips for an Excellent (Formal) Informal Communication Program

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One of the areas many compliance teams still struggle with is getting a consistent, effective informal communication plan off the ground. Eric has a few ideas that might help focus informal communication efforts at your organization. Eric talks about being realistic regarding time and resources and thinking strategically about what might reach your audience.

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