Recent US Department of Justice Commentary and the Impact on Compliance

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What does the Deputy Attorney General’s recent comments about various Department memorandum and informal statements mean for compliance and ethics. For more information on the DAG’s October statement, you can review this excellent commentary. The statement suggests that many of the DOJ memos discussing corporate prosecutions we are familiar with may be consolidated (or revoked).…

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Reflecting on the SCCE’s Compliance and Ethics Institute

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This time Eric reflects on the annual SCCE Compliance and Ethics Institute in Las Vegas. While there are certainly other compliance and ethics events, the size and scope of the CEI is impressive and we noted three themes this year that apply not to just CEI, but the profession in general. First, growth — and…

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Three Things To Know About Third-Party Risk

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Today Eric talks about third-party risks and some ideas for every organization to think about when thinking about third-party risk.

First, we encourage everyone to think outside the box and contemplate the actual third-party risks that their specific organization faces. We often think third-party risk just applies to organizations that operate overseas or have anti-corruption risks. Third-party risks are much broader and organizations should take time to consider it.

Second, Eric talks about how third parties are the “perfect storm” for risk. It’s hard to imagine any organization these days that doesn’t have third-party risk. Additionally, we talk a little about how third parties are logistically hard to monitor. Eric points out that despite these difficulties, organizations are liable for the actions taken on their behalf.

Third, there is a way to reasonable manage the risk organizations of all sizes and types face from third parties. Have a plan. Be consistent. Apply your limited resources based on a risk analysis. Guiding principles for due diligence include getting as much information about the third parties as you can, understanding the business rationale and establishing the ongoing relationship parameters.

Eric also talks a little about tiering or ranking risk. We list off several factors that you can consider when ranking the risk of a third party.

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Tone From the Top

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This time Eric talks about three practical areas to consider when evaluating and developing “tone from the top” at your organization. First, we examine what the expectations should be for the CEO or top executive of the organization. The CEO should be “present” in a real way and this can be measured by both the…

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Compliance & Ethics Institute Preview with SCCE’s Adam Turteltaub

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Adam Turteltaub

This week, we prepare to go to the annual SCCE CEI in Las Vegas. Recent events make the trip more somber, but we look forward to seeing old friends and meeting new ones. Eric speaks with SCCE’s Adam Turteltaub to discuss what’s new this year at the Compliance and Ethics Institute and some of the thought that goes into planning and organizing the annual event.

Eric also talks a little about the concept of “right action” and moving forward with your goals despite conflict.

It was a year ago that we launched Compliance Beat as we were preparing for the Institute. A big thank you to everyone out there that listens to us weekly. We hope to continue to provide interesting and useful content on compliance and ethics for years to come.

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What’s the ‘Bare Minimum’ Needed for Compliance? Part II

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What is the “bare minimum” an organization needs to have an effective compliance program?  Today we have part II of our discussion of what minimum requirements for an effective compliance and ethics program might be. Eric talks a little about the focus on organizational guidelines versus the Sentencing Guidelines as a whole. Eric also talks…

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What’s the ‘Bare Minimum’ Needed for Compliance? Part I

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ITUNES COVER

What is the “bare minimum” an organization needs to have an effective compliance program?  Is that even the right question?  Eric talks about a common inquiry that people often have about the “Seven Hallmarks” of the Sentencing Guidelines, and that is: what must we do? In Part I of a two-part series, Eric talks about…

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Effective Board of Directors Training, Part II

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Your board of directors must stay informed about their compliance duties and stay engaged in your compliance and ethics program to fulfill their obligations as board members.  Training your board of directors is a key responsibility for compliance professionals.  At times, training your board of directors can be a real challenge. In this second part of…

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Effective Board of Directors Training, Part I

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Your board of directors must stay informed about their compliance duties and stay engaged in your compliance and ethics program to fulfill their obligations as board members. Training your board of directors is a key responsibility for compliance professionals. At times, training your board of directors can be a real challenge. How can you effectively discuss compliance responsibilities and the key role of the board in compliance with board members, both new and old? What is the source law and standards for director’s responsibility for compliance? What risks do they face for not being on top of these responsibilities? Compliance is the responsibility of the full board, not just the audit or compliance committee. Eric talks about the expectations outlined in the Sentencing Guidelines and recent United States Department of Justice Fraud Sections’ new guidance, the Evaluation of Corporate Compliance Programs. Finally, Eric talks about how important it is to provide real information to the board about the content and operation of the organization’s specific compliance and ethics program.

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What Are Some Corporate Enforcement Myths?

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This time Eric tackles some common (and stubborn) myths about regulatory enforcement and criminal liability. First, we tackle the “Trump Factor”, and the notion that reduced regulation and enforcement is on the way. Eric talks about what we really are seeing with enforcement and the statements coming from regulators and prosecutors, including the USDOJ. Eric…

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