31 Days to More Effective Compliance Programs - Day 20 - Responding to Investigative Findings

Thomas Fox - Compliance Evangelist
Contact
One of the things rarely considered is how the investigation triggers the remediation process and the relationship between the two. When issues arise warranting an investigation that would rise to the Board of Directors level and potentially require disclosure to the government, there is usually a flurry of attention and activity. Everyone wants to know what is going on. In an interview with Russ Berland, CCO at Aventiv Technologies, he noted, “for that short moment in time, you have everyone’s full attention.” Yet it can still be “a See more +
One of the things rarely considered is how the investigation triggers the remediation process and the relationship between the two. When issues arise warranting an investigation that would rise to the Board of Directors level and potentially require disclosure to the government, there is usually a flurry of attention and activity. Everyone wants to know what is going on. In an interview with Russ Berland, CCO at Aventiv Technologies, he noted, “for that short moment in time, you have everyone’s full attention.” Yet it can still be “a tricky place because you get your fifteen minutes to get everyone’s full attention, and from then on, you’re fighting with everybody else for their attention, like the normal things in business life.”

Three key takeaways:

1. A serious FCPA allegation gets the attention of the Board and senior management. Use this time to move the compliance program forward.

2. Be aware of how your investigation can impact and even inform your remediation efforts.

3. Be prepared to deal with the dreaded “where else” question. See less -

Embed
Copy

Other MultiMedia by Thomas Fox - Compliance Evangelist

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

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.