31 Days to a More Effective Compliance Program-Day 29 | What is a root cause analysis?

Thomas Fox - Compliance Evangelist
Contact
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 -

Embed
Copy

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Thomas Fox - Compliance Evangelist | Attorney Advertising

Written by:

Thomas Fox - Compliance Evangelist
Contact
more
less

Thomas Fox - Compliance Evangelist on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide