This month, I will consider the risk management of third parties in an operationalized compliance program. As every compliance practitioner is well aware, third parties still present the highest risk under the Foreign Corrupt Practices Act (FCPA). The Department of Justice Evaluation of Corporate Compliance Programs devotes an entire prong to third party management. It begins with the following:

Risk-Based and Integrated ProcessesHow has the company’s third-party management process corresponded to the nature and level of the enterprise risk identified by the company? How has this process been integrated into the relevant procurement and vendor management processes?

This first set of queries clearly specifies the DOJ expects an integrated approach that is operationalized throughout the company. This means your compliance must have a process for the full life cycle of third party risk management. There are five steps in the life cycle of third party management.

  1. Business Justification and Business Sponsor;
  2. Questionnaire to Third Party;
  3. Due Diligence on Third Party;
  4. Compliance Terms and Conditions, including payment terms; and
  5. Management and Oversight of Third Parties After Contract Signing.

Over this month, I will be exploring each of these steps in detail so by the end of this month, you will be able to fully operationalize your third party risk management program.

Step 1 – Business Justification

The first step breaks down into two parts:

  1. Business Sponsor
  2. Business Justification

The purpose of the Business Justification is to document the satisfactoriness of the business case to retain a third party. The Business Justification should be included in the compliance review file assembled on every third party at the time of initial certification and again if the third party relationship is renewed.

Step 2 – Questionnaire

The term ‘questionnaire’ is mentioned several times in the 2012 FCPA Guidance. It is generally recognized as one of the tools that a company should complete in its investigation to better understand with whom it is doing business. I believe that this requirement is not only a key step but also a mandatory step for any third party that desires to do work with your company. I tell clients that if a third party does not want to fill out the questionnaire or will not fill it out completely that you should not walk but run away from doing business with such a party.

One thing that you should keep in mind is that you will likely have pushback from your business team in making many of the inquiries listed above. However, my experience is that most proposed agents that have done business with US or UK companies have already gone through this process. Indeed, they understand that by providing this information on a timely basis, they can set themselves apart as more attractive to US businesses.

Step 3 – Due Diligence

Most compliance practitioners understand the need for a robust due diligence program to investigation third parties, but have struggled with how to create an inventory to define the basis of risk of each foreign business partner and thereby perform the requisite due diligence required under the FCPA. Getting your arms around due diligence can sometimes seem bewildering for the compliance practitioner.

Our British compliance cousins of course are subject to the UK Bribery Act. In its Six Principles of an Adequate Procedures compliance program, the UK MOJ stated, “The commercial organisation applies due diligence procedures, taking a proportionate and risk based approach, in respect of persons who perform or will perform services for or on behalf of the organisation, in order to mitigate identified bribery risks.” The purpose of this principle is to encourage businesses to put in place due diligence procedures that adequately inform the application of proportionate measures designed to prevent persons associated with a company from bribing on their behalf. The MOJ recognized that due diligence procedures act both as a procedure for anti-bribery risk assessment and as a risk mitigation technique.

After you have completed Steps 1-3 and then evaluated and documented your evaluation, you are ready to move onto to Step 4 – the contract. In the area of compliance terms and conditions, the FCPA Guidance intones “Additional considerations include payment terms and how those payment terms compare to typical terms in that industry and country, as well as the timing of the third party’s introduction to the business.” This means that you need to understand what the rate of commission is and whether it is reasonable for the services delivered. If the rate is too high, this could be indicia of corruption as high commission rates can create a pool of money to be used to pay bribes. If your company uses a distributor model in its sales side, then it needs to review the discount rates it provides to its distributors to ascertain that the discount rate it warranted.

Step 4 – The Contract

You must evaluate the information and show that you have used it in your process. If it is incomplete, it must be completed. If there are Red Flags, which have appeared, these Red Flags must be cleared or you must demonstrate how you will manage the risks identified. In others words you must Document, Document and Document that you have read, synthesized and evaluated the information garnered in Steps 1-3. As the DOJ and SEC continually remind us, a compliance program must be a living, evolving system and not simply a ‘Check-the-Box’ exercise. 

Step 5 – Management of the Relationship

I often say that after you complete Steps 1-4 in the life cycle management of a third party, the real work begins and that work is found in Step 5– the Management of the Relationship. While the work done in Steps 1-4 are absolutely critical, if you do not manage the relationship it can all go downhill very quickly and you might find yourself with a potential FCPA or UK Bribery Act violation. There are several different ways that you should manage your post-contract relationship. Here we will explore some of the tools which you can use to help make sure that all the work you have done in Steps 1-4 will not be for naught and that you will have a compliant anti-corruption relationship with your third party going forward.

Final Thoughts

I continually give my Mantra of FCPA compliance, which is Document, Document, and Document. Each of the steps you take in the management of your third parties must be documented. Not only must they be documented but they must be stored and managed in a manner that you can retrieve them with relative ease. The management of third parties is absolutely critical in any best practices compliance program. As you sit at your desk pondering whether this assignment given to you by the CCO is a career-ending dead-end; you should take heart because there is clear and substantive guidance out there which you can draw upon.

Three Key Takeaways 

  1. Use the full 5-step process for 3rd party management.
  2. Make sure you have BD involvement and buy-in.
  3. Operationalize all steps going forward by including business unit representatives.


This month’s podcast series is sponsored by Opus. Opus helps free your business from the complexity and uncertainty of managing the risks associated with your customers, vendors, and third parties. By combining the most innovative Third-Party Risk Management and Know Your Customer Compliance SaaS platforms with unparalleled data solutions, Opus turns information into action so your business can thrive. Opus solutions include Hiperos ABAC Accelerator, the leading platform for third party risk management. To learn more, go to

I conclude my One Month to Operationalizing your Compliance Program series by discussing how you can put your compliance program at the center of corporate strategy. An article in the Harvard Business Review (HBR) by Frank Cespedes, entitled “Putting Sales at the Center of Strategy”, discussed how to connect up management’s new sales plans with the “field realities.” Referencing the well-known Sam Waltonism that “There ain’t many customers at headquarters”; Cespedes believes that “If you and your team can’t make the crucial connections between strategy and sales, then no matter how much you invest in social media or worry about disruptive innovations, you may end up pressing for better execution when you actually need a better strategy or changing strategic direction when you should be focusing on the basics in the field.”

This can be a critical problem when operationalizing compliance because operationalizing compliance is usually perceived as a top-down exercise. The reality that the employee base that must execute the compliance strategy is not considered. Even when there are comments from employees on compliance initiatives they are often derisively characterized as ‘push-back’ and not taken into account in moving the compliance effort forward.

Communicate the Strategy

It can be difficult for an employee base to implement a strategy that they do not understand. Even with a company wide training rollout, followed by “a string of e-mails from headquarters and periodic reports back on results. There are too few communications, and most are one-way; the root causes of underperformance are often hidden from both groups.” Here Cespedes’ insight is that clarification is a leadership responsibility and in the compliance function that means the Chief Compliance Officer (CCO) or other senior compliance practitioner. Moreover, if the problem is that employees do not understand how to function within the parameters of the compliance program, then there is a training problem and that is the fault of the compliance department. I once was subjected to a PowerPoint of 268 slides, which lasted 7.5 hours, about my company’s compliance regime. To say this was worse than useless was accurate. The business guys were all generally asleep one hour into the presentation as we went through the intricacies of the books and records citations to the FCPA. The training was a failure but it was not the fault of the attendees. If your own employees do not understand your compliance program that is your fault.

Continually improve your compliance productivity

Why not do the incentivize productivity around compliance? Work with your Human Resources (HR) department to come up with appropriate financial incentives. Many companies have ad hoc financial awards, which they present to employees to celebrate and honor outstanding efforts. Why not give out something like that around doing business in compliance? Does your company have, as a component of its bonus compensation plan, a part dedicated to compliance and ethics? If so, how is this component measured and then administered? There is very little in the corporate world that an employee notices more than what goes into the calculation of their bonuses. HR can, and should, facilitate this process by setting expectations early in the year and then following through when annual bonuses are released. With the assistance of HR, such a bonus can send a powerful message to employees regarding the seriousness with which compliance is taken at the company. There is nothing like putting your money where your mouth is for people to stand up and take notice.

Improve the human element in your compliance program

This is another area where HR can help the compliance program. More than ongoing assessment of employees for promotion into leadership positions, here HR can assist on the ground floor. HR can take the lead in asking questions around compliance and ethics in the interview process. Studies have suggested that certainly Gen Y & Xers appreciate such inquiries and want to work for companies that make such business ethics a part of the discussion. By having the discussion during the interview process, you can not only set expectations but you can also begin the training process on compliance.


However, this approach should not end when an employee is hired. HR can also assist your compliance efforts by tracking employees through their company career to identify those who perform high in any compliance metric. This can also facilitate the delivery on more focused compliance training to those who may need it because of changes on compliance risks during their careers.

Make your compliance strategy relevant

Cespedes notes, “Most C-suite executives know these value-creation levers, but too few understand and operationalize the sales factors that affect them.” In the sales world this can translate into a reduction in assets to underperforming activities. This is all well and good but such actions must be coupled with an understanding of why sales might be underperforming in certain areas. In the compliance realm, I think this translates into two concepts, ongoing monitoring and risk assessment. Ongoing monitoring can allow you to move from a simple prevent mode to a more prescriptive mode; where you can uncover violations of your company’s compliance program before they become full blown FCPA violations. By using a risk assessment, you can take the temperature of where and how your company is doing business and determine if new products or service offerings increase your compliance risks.

Above all, you need to get out and tell the compliance story. Louis D’Amrosio was quoted for the following, “You have to repeat something at least 10 times for an organization to fully internalize it.” If there is a disconnect between your compliance strategy and how your employee base is implementing or even interpreting that strategy, get out of the office and go out to the field. But you need to do more that simply talk you also need to listen. By doing so, can help to align your company’s compliance strategy with both the delivery and in the field.

Three Key Takeaways

  1. Use information from your employees to make your compliance program more productive.
  2. Use social media and other innovative techniques to communicate your compliance strategy.
  3. Operationalize Operationalize Operationalize, then Document Document Document. 


This month’s podcast series is sponsored by Oversight Systems, Inc. Oversight’s automated transaction monitoring solution, Insights On Demand for FCPA, operationalizes your compliance program. For more information, go to

The Evaluation of Corporate Compliance Programs, Prong 6, Incentives and Disciplinary Measures states:

Incentive SystemHow has the company incentivized compliance and ethical behavior? How has the company considered the potential negative compliance implications of its incentives and rewards? Have there been specific examples of actions taken (e.g., promotions or awards denied) as a result of compliance and ethics considerations?

How can you measure compliance in senior management or evaluate it for the purposes of a bonus calculation? This issue has often been difficult to sustain in a company because the compliance evaluation of whether a senior manager or company leader is often viewed as too subjective. An article entitled, “Integrating Your Compliance Programme Into the Variable Compensation of Executives, addressed these issues and concerns.

The article was built around a case study of the Sorin Group, a healthcare multinational, and the company’s incentive program for its compliance regime. The company created such an incentive program to “influence actual behaviors, and not merely the consequences of any wrong doing that may occur.” Compliance has been made an integral part of each manager’s performance objectives. Members on the company’s Executive Leadership Team (ELT) and the other leaders of all its corporate functions and “business units are directly responsible for the culture, understanding, observance and adoption of the Sorin Code of Conduct, the Sorin United States and international compliance policies and procedures” and their respective health industry codes of practice.

Each of the different functions within the Sorin Group has adopted individual performance objectives specifically regarding compliance. The individualized “compliance objectives are agreed and documented every year for each function and senior manager, and form part of the process of continuous performance review (written reviews twice yearly) managed by Sorin’s human resources team. The responsible executive of each function or group is required to cascade each of the compliance obligations to those employees under them. This ensures that the whole company has compliance integrated into their variable remuneration.”

The company’s evaluation process includes the staff that report to each senior executive who are interviewed by the General Counsel (GC) or other member of the compliance function “to determine their adherence to the compliance objectives.” Additionally, “An assessment is performed alongside line managers and a member of the human resources team to determine whether the obligations have been met, and to what extent.” Lastly, this same system applies to the company’s Board of Directors and Chief Executive Officer (CEO).

The variable compensation awarded at the end of each year can be affected in two ways by this compliance evaluation. The first is for an entire group and “If a group fails to meet expectations for the specific objectives the executive and their whole team will miss out on the entire variable pay for that year.” But “If a group meets some expectations for the compliance objectives they will receive payment of the variable, with the amount dependent on the amount of objectives that have been met.” The same holds true for the individual within the group so that “if an employee fails to meet his or her compliance objectives, the whole bonus for that employee will remain unpaid.”

Some examples of compliance obligations that are measured and evaluated include the following:

For the ELT

  • Lead from the top – in your own conduct (lead by example) and in the decisions you take, to the resources and time you commit to compliance;
  • Facilitate and proactively practice in day-to-day activities the key compliance competencies, both internally and externally; and
  • Support specific initiatives from the CCO, compliance function. 

For Department Heads

  • Demonstrate, facilitate and proactively practice in day-to-day activities the key compliance competencies, both internally and externally;
  • Support specific initiatives from the compliance function;
  • Ensure that all employees, agents and contractors directly or indirectly reporting to you fully complete all required training and communications in a timely manner;
  • Provide full cooperation with investigations conducted by the compliance or legal functions of any alleged violation of compliance policies;
  • Include the Chief Compliance Officer or another legal or compliance function representative in your management meetings at least twice per year, per geography;
  • Identify instances of non-compliance and support compliance monitoring and reporting systems; and
  • Partner with compliance in resolving compliance issues.

For Country Heads of Sales

  • Certify that all employees, agents and contractors directly or indirectly reporting to you have fully reported all sales and marketing interactions with all government officials or employees of state-owned enterprises in a timely manner and
  • Certify that all employees, agents and contractors directly or indirectly reporting to you have fully, promptly and accurately reported all expenses with government officials or employees of state-owned enterprises on ERP.

The article also speaks of five things to consider when developing such a compliance incentive program.  (1) The program needs to be cascaded down the organization so that it applies to all levels in the company. (2) Include both a 360 degree review and mid-year review. (3) To truly incentive senior management, the compliance objectives should be at least 25% of the overall discretionary bonus program. (4) Do not have simply ‘tick-the-box’ incentives but include subject incentives.

As the final item to consider, is you need to have SMART compliance objectives, which are defined as:

  • Specific: A specific objective has a much greater chance of being accomplished than a general objective (e.g don’t just say “ensure training has been completed by your team”, say;
    • Who: who needs to be trained?
    • What: what training objectives do you want to accomplish?
    • Where: identify a location for the training
    • When: establish a time frame for the training to be completed
    • Which: identify requirements and constraints for any training
    • Why: provide specific reasons, purpose or benefits of accomplishing the training objective.
  • Measurable: Establish concrete criteria for measuring progress toward the attainment of each objective you set.
  • Aggressive but attainable: When you identify objectives that are most important to the compliance function and the relevant business, employees are more likely to see the value in making them come true.
  • Realistic: To be realistic, an objective must represent something which you are both willing and able to work toward.
  • Timely: An objective should be grounded within a timeframe.

The article ends with some insights into lessons learned, including the following:

  • Top down: If your ELT is truly on board you can make big leaps and not limit your compliance ambitions to incremental steps.
  • Personalize: The objectives should be more personal to each function and more granular.
  • Balance: Have qualitative judgments but couple them with concrete and – most importantly – objective and measurable key performance indicators.
  • Publicize: Talking about the real company examples of its people make the difference.
  • Be positive: Focus your company’s efforts on positive incentive behaviors. In other words, use both the stick and carrot.
  • Just do it: Stop talking the talk and start walking the walk.

The Evaluation makes clear that the Department of Justice expects incentives to be operationalized into your compensation structure. While there may always be subjectivity built into any compensation incentive system, that does not mean financial incentives cannot be written into the evaluation of any senior management to help guide ethical business practices.

Three Key Takeaways

  1. The Evaluation requires not only carrots around compliance but metrics to justify compensation.
  2. Provide metrics for each level of employee to hit as a part of a discretionary bonus evaluation.
  3. Up to 25% of a discretionary bonus should be based on compliance or an ethical component. 

This month’s podcast series is sponsored by Oversight Systems, Inc. Oversight’s automated transaction monitoring solution, Insights On Demand for FCPA, operationalizes your compliance program. For more information, go to

Even with a great Tone-At-the-Top and in the middle, you cannot stop. One of the greatest challenges of a compliance practitioner is how to affect the ‘tone at the bottom’. In an article in the Spring 2012 Issue of the MIT Sloan Management Review, entitled “Uncommon Sense: How to Turn Distinctive Beliefs Into Action”, authors explored the “often overlooked, critical source of differentiation is [a] company’s beliefs” and provided techniques on how to tap into these beliefs. The authors listed seven approaches that they have used which I believe that the compliance practitioner can use to not only determine ‘Tone at the Bottom” but to impact that tone. They are as follows:

  1. Assemble a group. You need to assemble a group of employees who are familiar with the challenges of doing business in a compliant manner in certain geographic regions. Include both long-time employees and those who are relatively new to the organization. The authors also suggest that if you have any employees who have worked for competitors or for other organizations in your industry you include them as well.
  2. Ask questions. You should ask the members of this group to articulate their basic assumptions about your compliance model, about the management model, about your company’s business model and the future of the industry in general. Ask them to do this individually and not as a group.
  3. Categorize the responses. Now comes the work by the compliance practitioner or compliance team. These assumptions will usually fall into two groups. The first is assumptions that everyone agrees upon-the common beliefs. The second is those assumptions that only a few of the participants will identify – this is what the authors call the “uncommon beliefs”.
  4. Develop tests for common beliefs. For those beliefs that are labeled common – you should consider how you know these to be true? The authors caution that simply because the group may believe that the company operates a common industry or that we “do it because it has always been done this way” is necessarily a “hard fact.” Consider what test you could perform to verify the common belief that you desire to test. The authors note that the purpose here is to “identify the ‘common nonsense’ beliefs that everyone holds that are not actually hard laws of nature.”
  5. Develop tests for uncommon beliefs. Here the authors suggest that you need to consider why some people think that these beliefs are true. What is the information or experience that they have drawn upon? Is there any way for you to test these uncommon beliefs?
  6. Reassemble the original group. You should reassemble the original group and have them consider the beliefs that were articulated by them individually in the context of your compliance model and how both your company and your industry do business. Lead a discussion that attempts to identify any assumptions or beliefs that ‘are quite possibly wrong, but worth experimenting with anyway.”
  7. List of Experiments to perform. The authors believe that the outcome of the first six steps will be “a list of possible experiments [tests] to conduct” to determine the validity of the common and uncommon beliefs. These tests can be accomplished in the regular course of business, through a special project with a special team and separate budget. You should agree on the testing process and review your testing assumptions throughout the process. This process can and should take some time so do not set yourself such a tight time frame that it cannot be fully matured.

By engaging employees at this level, you can find out not only what the employees think about the company compliance program but use their collective experience to help design a better and more effective compliance program. Employees want to do business in an ethical manner. Given the chance to engage in business the right way, as opposed to cheating; will win the hearts and minds of your employees almost all the time. By using the protocol suggested by the authors you can not only find out the effect of your company’s compliance program on the employees at the bottom but you can affect it as well.

Mike Volkov said in an article entitled, “Mood in the Middle Versus Tone at the Top” that “Even when a company does all the right things at the senior management level, the real issue is whether or not that culture has embedded itself in middle and lower management.  A company’s culture is reflected in the values and beliefs that exist throughout the company.” To fully operationalize your compliance program, you must find a way to articulate and then drive the message of ethical values and doing business in compliance with such anti-corruption laws such as the FCPA from the top down, throughout your organization.

Three Key Takeaways

  1. How is your compliance embedded at the bottom of your organization?
  2. Use of social media can help set the tone at the bottom.
  3. A company’s culture is reflected in the values and beliefs that exist throughout the company-make certain you assess it and use that information going forward. 

This month’s podcast series is sponsored by Oversight Systems, Inc. Oversight’s automated transaction monitoring solution, Insights On Demand for FCPA, operationalizes your compliance program. For more information, go to

Under the Evaluation of Corporate Compliance Programs, Prong 2, it states:

  1. Senior and Middle Management

Conduct at the Top – How have senior leaders, through their words and actions, encouraged or discouraged the type of misconduct in question? What concrete actions have they taken to demonstrate leadership in the company’s compliance and remediation efforts? How does the company monitor its senior leadership’s behavior? How has senior leadership modelled proper behavior to subordinates?

This requirement is more than simply the ubiquitous ‘tone-at-the-top’ as here the Justice Department wants to see a company’s senior leadership actually doing compliance. How can senior management operationalize compliance going forward? One of the best places to start is the article from the Harvard Business Review by Professor Lynn Paine entitled, “Managing for Organizational Integrity”. Larry Thompson, former PepsiCo Senior Vice President of Governmental Affairs, General Counsel and Secretary, discussed the work of Professor Paine in citing five factors, which he believed were critical in establishing an effective integrity program and to set the right “Tone at the Top”.

  1. The guiding values of a company must make sense and be clearly communicated.
  2. The company’s leader must be personally committed and willing to take action on the values.
  3. A company’s systems and structures must support its guiding principles.
  4. A company’s values must be integrated into normal channels of management decision-making and reflected in the company’s critical decisions.
  5. Managers must be empowered to make ethically sound decisions on a day-to-day basis.

David Lawler, in his book, Frequently Asked Questions in Anti-Bribery and Corruption  boiled it down as follows “Whatever the size, structure or market of a commercial organization, top-level management’s commitment to bribery prevention is likely to include communication of the organization’s anti-bribery stance and appropriate degree of involvement in developing bribery prevention procedures.” Lawler went on to provide a short list of points that he suggests senior management engage in to communicate the type of tone to follow an anti-corruption regime.” I had a CEO of a client, who after I described his role in operationalizing his company’s compliance program observed the following, “You want me to be the ambassador for compliance.” I immediately averred in the affirmative. The following is a list of things that a CEO can do as an ‘Ambassador of Compliance’

  • Reject a ‘do as I say, not as I do’ mentality;
  • Not just ‘talk-the-talk’ but ‘walk-the-walk’ of compliance;
  • Oversee creation of a written statement of a zero tolerance towards bribery and corruption;
  • Appoint and fully resource, with money and headcount, a Chief Compliance Officer;
  • Oversee the development of a Code of Conduct and written compliance program implementing it;
  • Ensure there are compliance metrics on all key business reports;
  • Provide leadership to middle managers to facilitate filtering of the zero tolerance message down throughout the organization;
  • Not only have a whistleblowing, reporting or speak up channel but celebrate it;
  • Keep talking about doing the right thing;
  • Make sure that you are seen providing your Chief Compliance Officer with access to yourself and the Board of Directors.

Coming at it from a different perspective, author Martin Biegelman provides some concrete examples in his book entitled, “Building a World Class Compliance Program – Best Practices and Strategies for Success”. Biegelman begins the chapter discussed in this posting with the statement “The road to compliance starts at the top.” There is probably no dispute that a company takes on the tone of its top management. In this chapter Biegelman cites to a list used by Joe Murphy of actions that a CEO can demonstrate to set the requisite tone from the Captain’s Chair of any business. The list is as follows:

  1. Keep a copy of the Constitution on your Desk. Have a dog-eared copy of your company’s Code of Conduct on your desktop and be seen using it.
  2. Clout. Make sure your compliance department has authority, influence and budget within the company. Have your Chief Compliance Officer (CCO) report directly to the Board of Directors.
  3. Make them Accountable. At Senior Executive meetings, have each participant report on what they have done to further the compliance function in their business unit.
  4. Sticks and Carrots. Have both sanctions for violation of company compliance and ethics policies and incentives for doing business in a compliant manner.
  5. Don’t do as I say, Do as I do. Turn down an expensive dinner or trip offered by a vendor. Pass on a gift that you may have received. Turn down a transaction based upon ethical considerations.
  6. Be a Student. Be seen at intra-company compliance training. Take a one or two day course or attend a compliance conference outside your organization.
  7. Award Compliance. You should recognize outstanding compliance efforts with companywide announcements and awards.
  8. The Board. Recruit a nationally known compliance expert to sit on your company’s Board and chair the audit or compliance committee.
  9. Independent Review. Obtain an independent, outside review of your company’s compliance program and report the results to the Board’s Audit Committee.
  10. Mandate that all vendors in your Supply Chain embrace compliance and ethics as a business model. If not, pass on doing business with them.
  11. Talk to others in your industry and your peers on how to improve your company’s compliance efforts.

Many companies struggle with some type of metric which can be used for upper management regarding compliance and communication of a company’s compliance values. One technique might be to require the CEO to post companywide emails or other communications once a quarter on some compliance related topic. The CEO’s direct reports would then also be required to email their senior management staff a minimum of once per quarter on a compliance topic. One can cascade this down the company as far as is practicable. Reminders can be set for each communication so that all personnel know when it is time to send out the message. If these communications are timely made, this metric has been met.

Three Key Takeaways

  1. Senior management must actually do compliance; walk-the-walk, not simply talk-the-talk.
  2. Use your CEO to talk about current events and how those ethical failures are lessons to be learned for your organization.
  3. CEO as Compliance Ambassador.


This month’s podcast series is sponsored by Oversight Systems, Inc. Oversight’s automated transaction monitoring solution, Insights On Demand for FCPA, operationalizes your compliance program. For more information, go to