One new and different item laid out in the 2017 Evaluation, supplementing the Ten Hallmarks of an Effective Compliance Program from the 2012 FCPA Guidance, was the performance of a root cause analysis for any compliance violation which may led to a self-disclosure or enforcement action.
Three key takeaways:
1. A root cause analysis is now required if See more +
One new and different item laid out in the 2017 Evaluation, supplementing the Ten Hallmarks of an Effective Compliance Program from the 2012 FCPA Guidance, was the performance of a root cause analysis for any compliance violation which may led to a self-disclosure or enforcement action.
Three key takeaways:
1. A root cause analysis is now required if you have a reportable compliance failure.
2. There is no one process for performing a root cause analysis. You should select the one which works for you and follow it.
3. To properly perform a root cause analysis, you need trained professionals who really understand what they’re doing. See less -