It may seem like a Herculean task — but it can be done. I regularly opine that mitigating sanctions risks for your third-party population is an easier task than doing so for your anti-corruption risks. One big reason — geography is an important limiter on sanctions risks. The ability to evade sanctions has to be financially practicable — for example, it makes no sense to...
Within the specific element discussions in HHS-OIG’s Guidance, are important operational details and strategies for an effective compliance program. GCPG provides important suggestions and innovations for consideration by all compliance professionals. Effective Lines of Communication The GCPG stresses the importance of an open line of communication between the compliance officer and entity personnel as a means to reduce potential fraud, waste and abuse. To this...
It is easy to be overwhelmed by the overall risk profile of your third-party population. The best way to tackle the problem is by defining specific problems and risks and then analyzing a subset of third parties as to this specific problem or risk. On the operational side, the business can guide this inquiry, especially procurement professionals who should be familiar with the direct and...
I am not one to engage in hyperbole. But when it comes to blockchain technology and the implications for our economy, this is going to be the real deal. In the world of ethics and compliance, blockchain has many possible applications that could easily transform compliance capabilities. To show my age, let’s go back into time and remember when we all were buying personal computers...
Following FCPA enforcement actions provides important insights that can be translated into corporate compliance program best practices. One key element of an effective ethics and compliance program is conducting periodic assessments, and implementing an efficient and responsive internal investigation protocol. Under the Sentencing Guidelines, an effective ethics and compliance program has to prevent and detect potential violations of law and the company’s code of conduct....
