It is with no small amount of pride that I am able to announce the publication and availability of my 16thbook, The Complete Compliance Handbook, on Monday, May 21, 2018. Written in the space of a little over one-year, this book incorporates the most recent pronouncements and guidance from the Department of Justice (DOJ), including 2017’s Evaluation of Corporate Compliance Programs (Evaluation) and FCPA Corporate Enforcement Policy, to provide the most up-to-date advice on what constitutes a best practices compliance program. This single volume compendium brings together the top ideas, topics and techniques you can incorporate your compliance program, literally in 365-days to more fully operationalize your compliance regime. If you want one volume to guide you in operationalizing compliance, this is it.
For several years, I have wanted to write a definitive, single volume on what constitutes a best practices compliance program. I decided in 2017 to bite the bullet and dedicate the year to writing it. It turned into a journey of discovery as I was able to interview many of the country’s leading compliance practitioners and others to incorporate the most current thinking into the book. I learned many new things, most particularly about the evolution of the top thinking on what constitutes abest practicescompliance program some five years after the DOJ and Securities and Exchange Commission’s (SEC’s) seminal publication, A Resource Guide to the U.S. Foreign Corrupt Practices Act, which was released in 2012.
Building up the 2012 FCPA Guide’s Ten Hallmarks of an Effective Compliance Program, I wanted to consider the advancements from the legal, regulatory, technological and innovation perspective for the compliance practitioner. The book is designed to provide you with a step-by-step guide to the design, creation, implementation of or enhancement to a compliance program. It begins with 31-days to a more effective compliance program. Each entry presents one thing you can accomplish, at little to no cost, to improve any level of compliance program. There are three key-takeaways for each entry. The final chapter goes through the same process for you to operationalize your compliance program. In between these bookends, The Complete Compliance Handbookfeatures chapters on:
- Operationalizing Compliance Through Human Resources – Why and how Human Resources (HR) should be a key corporate discipline in operationalizing a best practices compliance program. What are the places in the full employment lifecycle of every employee that HR can bring a compliance component to more fully operationalize your compliance regime?
- The Role of the Board of Directors and Compliance – In every recent corporate scandal, the question is always, Where was the Board?That role has become increasingly important.
- 360-Degrees of Communication in Compliance – Compliance communication has evolved. Current best practices are not upward, downward, inbound or outbound but a communication strategy to fully encapsulate all compliance actions and touchpoints with the full spectrum of the compliance customer base. How can you use social media to create a more robust compliance dialogue in your organization?
- Better Third-Party Risk Management – Still the highest risk in any anti-corruption compliance program. I lay out the specific program under which you can manage the full spectrum of the life cycle of third-party risk management.
- Reporting and Investigations – How well used is your hotline? Do you receive reliable tips and information from your employee base? How do you triage hotline reports and what is your investigation protocol? Find out the best practices to these and other issues.
- Internal Controls – How robust are your compliance internal controls? Have you performed a gap analysis to ascertain what you might have in place? Robust compliance internal controls can make your company run more efficiently.
- Innovation in Compliance – Compliance has become one of the most truly innovative corporate disciplines. What are you doing to keep your compliance program abreast of the most recent innovations in compliance? What innovations from areas outside the compliance profession will have the most impact on compliance programs going forward? How will Artificial Intelligence (AI) make compliance more robust?
- Written Standards – These form the very backbone of every compliance program. They include your Code of Conduct, policies and procedures. How did you design and tailor these documents to your company’s risks and your corporate culture? When was the last time your written standards were updated? Find out the best practices for all areas of written standards.
- More Effective Compliance for Business Ventures – The range of business partners and partnerships is only limited by the imagination of the business folks involved. How do you manage the compliance risks in ventures as diverse as joint ventures (JVs), franchises, teaming agreements, 4thtier subcontractors and partnerships? This chapter also considers best practices for mergers and acquisitions (M&A).
- Continuous Improvement – What are the current best practices for ongoing monitoring and continuous improvement of your compliance program? Most compliance practitioners are aware of auditing and monitoring but how do the new technological tools allow you to literally see “patterns in the raked leaves” of your company’s data. Why is continuous improvement no longer simply a nice-to-have but a mandatory component of any best practices compliance program?
When you couple all of the latest techniques, innovation and advancements in compliance over the past five years, together with the most recent DOJ pronouncements in the form of the Evaluation and FCPA Corporate Enforcement Policy; you can see why I wanted to write this book and why it will be helpful to the compliance practitioner and compliance profession. There is literally no other book out today with the most recent information on what constitutes a best practices compliance program.
I hope you will check it out. If you do, I know you will not be disappointed.
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If you want one volume to guide you in operationalizing compliance, The Compliance Handbook is it.Click to tweet
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© Thomas R. Fox, 2018