In honor of David Prowse, the original actor portraying Darth Vader, I am running a podcast series this week on the intersection of compliance and Star Wars. Today, we consider Episode IV, A New Hope and risk.
One of the plotlines is that the Galactic Empire has created a Death Star with enough firepower to destroy a planet. The Rebel Alliance is See more +
In honor of David Prowse, the original actor portraying Darth Vader, I am running a podcast series this week on the intersection of compliance and Star Wars. Today, we consider Episode IV, A New Hope and risk.
One of the plotlines is that the Galactic Empire has created a Death Star with enough firepower to destroy a planet. The Rebel Alliance is determined to destroy the Death Star and has blueprints detailing the defensive posture of the Death Star. A computer analysis determines a weakness in the Death Star’s defensive shield. At one point, the Death Star’s commander, Grand Moff Tarkin, is told there is a ‘risk’ in the Rebel’s plan of attack. Tarkin dismisses this risk as insignificant. Of course, Luke Skywalker then proceeds to exploit this risk and destroy the Death Star.
Tarkin’s incorrect assessment of this risk was lethal. Today I want this part of the story to introduce the subject of how you evaluate compliance risk under the FCPA or an economic sanctions regime. Failure to appreciate risk can lead to some very serious and perhaps lethal consequences.
Whether you utilize one approach or another, analyzing the results of your risk assessment is as important as doing the risk assessment. With the recent Department of Justice (DOJ) remarks around how they will review the effectiveness of compliance programs during an enforcement action to determine potential credit or even granting a declination, the stakes have never been higher. Of course, for Grand Moff Tarkin, his refusal to analyze the risk assessment presented to him was fatal.
Join us tomorrow where we consider The Empire Strikes Back and due diligence. See less -
