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Compliance Podcast Network – Over a series of blog posts, Tom Fox lays out what he believes are the top ten lessons for compliance professionals to be learned from recent DOJ and SEC FCPA enforcement actions.
Over the past 15 months, the DOJ and SEC have made clear through these actions their priorities in investigations, remediations, and best practices compliance programs. Every compliance professional should study these enforcement actions closely for the lessons learned and direct communications from the DOJ. They should guide not simply your actions should you find yourself in an investigation but also how you should think about priorities.
Source: Ten Top Lessons from Recent FCPA Settlements
- Self-Disclosure
- The Need for Speed
- Extensive Remediation
- Start with a Root Cause Analysis
- Data Analytics
- Clawbacks and Holdbacks
- Changing Your Business Model
- Enhancing Your Compliance Program
- Internal Controls
- Getting to Self-Disclosure: Speak Up, Triage and Internal Investigation
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