31 Days to More Effective Compliance Programs - Day 22 - Internal Reporting and Triaging Claims

Thomas Fox - Compliance Evangelist
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Given the number of ways that information about violations or potential violations can be communicated to the government regulators, having a robust triage system is an important way to determine what resources to bring to bear on a compliance problem.

Jonathan Marks has articulated a five-stage triage process that allows for an early assessment of any allegations and a manner to think through your investigative approach. Marks cautions you See more +

Given the number of ways that information about violations or potential violations can be communicated to the government regulators, having a robust triage system is an important way to determine what resources to bring to bear on a compliance problem.

Jonathan Marks has articulated a five-stage triage process that allows for an early assessment of any allegations and a manner to think through your investigative approach. Marks cautions you must have an experienced investigator or other seasoned professional making these determinations, if not a more well-rounded group or committee. Next, consider the types of evidence to review going forward. Finally, before selecting a triage solution, understand what tools are available, including forensic and human, to complete the investigation.

Three key takeaways:

1. The DOJ and SEC put special emphasis on internal reporting lines.

2. Test your hotline regularly to make sure it is working.

3. Every claim should be triaged before starting an investigation. See less -

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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.

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