Most Asked Questions About Effective Compliance Programs On Part 1 And 2

CCOs are increasingly expected to act not as niche specialists, but as top level advisors who understand a company’s business needs.

CCOs are focusing less on high level compliance in favor of more department-specific compliance.

CCOs are focusing more on legal issues than ever before.

It is more important than ever for CCOs to possess strong interpersonal skills, like listening and problem solving.

Avoiding conflicts of interest

Fostering psychological safety in the workplace

Ensuring that every employee feels a personal responsibility for complying with relevant rules and regulations

Ensuring that every employee recognizes and accepts the company’s compliance program

An effective training and awareness program

Exclusion of individuals known, through due diligence, to be engaged in illegal activities or other compliance or ethics-related misconduct

Consistent enforcement through discipline

All of the above are codified in the FSG

CCOs should conduct risk assessments before crafting risk management policies and procedures.

CCOs should integrate themselves with and report to business units that face particular compliance challenges.

To avoid confusion, CCOs should report to a singular person or entity, whether it be the CEO or a compliance committee.

Tolerating employee misconduct threatens a company’s attempt to create a “tone at the top” that is conducive to compliance.

The Code of Ethics

Compliance with applicable governmental laws, rules and regulations

Accountability for adherence to the code

Full, fair, accurate, timely and understandable disclosure
Efficiency in company operations

To convey what is permitted and prohibited on a daily basis

To create the illusion of compliance

To ensure that employees have easily digestible ethical guidelines accessible to them at all times

To create a document that will be referenced by both senior management and lower level employees

Communication & Information Flows

True

False

True

False

True

False

Correct

Correct – a company that has dealt with compliance failures can, in some cases, emerge with a stronger and more robust compliance program.

Module 2

Ensure that polices are circulated and reviewed by different departments before being formally adopted.

Share customer information only with vendors that have not experienced compliance failures in the past.

When training employees, acknowledge that everyone has a different view of what compliance means.

Ensure that the public knows where it can report ethical violations or compliance failures.

Comply with Pay-to-Play laws prohibiting certain campaign contributions

Monitor employees’ emails on a regular basis

Monitor which employees have access to restricted floors, offices, or data rooms

Review and report on the personal securities transactions of certain employees.

True

False

Notify a senior executive that there has been a compliance breach.

Explore further to determine the reason for the anomalous receipts.

Discipline the employee in accordance with the company’s Code of Conduct.

Send an email to all employees reminding them of the company’s spending and reimbursement policy.

It can prevent potential problems from maturing into real problems.

It is required in most industries.

It can give the compliance department a good idea of what is going on at the company.

It enforces good email practices.

is an aspirational rather than practical document.

Sets the tone for the way employees are supposed to act.

Should be the bedrock of a compliance program.

is mandatory for companies to establish in most industries.

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Most Asked Questions About Effective Compliance Programs On Part 1 And 2