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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Should We Measure Our Case Management and Reporting System? What Are Some Ways to Measure?

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This time Eric discusses case management and reporting benchmarking. First, why is it a good idea to have a plan in place to gauge the effectiveness of this aspect of your compliance program? Eric explores why it’s a good idea to have a business case put together so that you can budget for tools in…

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A Special Conversation with Ricardo Pellafone

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In this episode Eric has a conversation with Ricardo Pellafone, the founder of Broadcat. Eric and Ricardo have a wide-ranging discussion about compliance myths that seem to have a lot of staying power. Including, how having a lot of resources and being very busy does not necessarily equal an “effective” program. As Ricardo paraphrases Hui…

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Who Should Be Involved in a Code of Conduct Revision Project?

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In this episode Eric delves in a little deeper on a common question: who should be involved in a code of conduct project? Of course this depends a lot on what kind of project is being undertaken. Should you revise internally or bring in an outside team? What resources are available to your organization to…

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Is It Good To Be a “Famous” Compliance Officer?

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Interesting doings at the Department of Justice, and other recent issues have brought forward the notion of how valuable (or not) is it for an organization’s compliance officer to be “famous” or have a high profile in (or outside) the organization. Compliance officers want to market and communicate about their programs, of course, but what…

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Do The Sentencing Guidelines Matter Anymore?

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Recently we’ve seen more activity from the Department of Justice (Fraud Section) and other regulators both in the United States and internationally that address compliance and ethics program standards and effectiveness. One topic that’s come up informally in some conversations is whether the Sentencing Guidelines still hold a central role in defining “effectiveness” for a…

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Tips for Compliance and Ethics Program Incentives

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Since incentives were first introduced in the Sentencing Guidelines there has been little guidance about what exactly make up incentives for compliance. It’s also probably no surprise that one of the most underdeveloped parts of many compliance and ethics programs is the application of incentives. In this episode Eric talks about some practical things organizations…

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Using the Web: Should You Have a Web-Based Code of Conduct?

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Should you have a web-based code of conduct? A common question that many organizations have when they are updating their code of conduct is should the code be a web-based document? If not, how might an organization use both internal and external-facing web resources? Eric has some ideas about adapting the code, and code content,…

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