A sample vendor assessment questionnaire from the ACC 2014 Compliance & Ethics Training Program, Session 600.
Discuss the remaining specific challenges facing the compliance officer today; understand how to research your industry's specific compliance needs; learn about some of the hottest compliance issues that are seeing greater enforcement now; and discuss emerging regulatory schemes that could prove troubling for your organization.
Review key provisions of the FCPA, UK Bribery Act, CFPOA, OECD, Brazil’s anticorruption law and others; highlight the extraterritoriality of each regulation and the impact on global businesses, incorporating recent enforcement actions; explore the local responsiveness vs. global efficiency debate, and how cultural norms impact the effectiveness of corporate compliance programs; and Discuss practical approaches to understanding and mitigating risks. (Topics of interest may include screening suppliers, distributors and agents, and drafting, maintaining and enforcing contractual provisions.)
Understand the global legal and regulatory landscape of data privacy, specifically how it relates to the transfer of data across borders; discuss the role of the in-house attorney as a privacy professional; learn the valuable role the information security officer plays in developing and maintaining data privacy, and the importance of creating a cooperative relationship; understand which components of the data protection umbrella are the domain of the info security team (tech) and which are the domain of the data privacy team (legal); and Learn to assess the risks of your current data privacy protocols.
Discuss the various roles in-house counsel tend to play, and how they are affected by attorney-client privilege rules; learn about attorney-client privilege rules from around the world and how they apply in the compliance context; discuss in depth the Professional Conduct Model Rules 1.6, 1.13 and others as appropriate; and discuss the pros and cons of non-lawyers assuming compliance roles.
Compile information from earlier sessions that will help convince your CEO that you need to implement an effective compliance program or revamp your current program; Understand how to manage your CEO’s expectations and deliver positive results; take away benchmarks and statistics that will help convince your executives to act before there’s a problem; and receive a pre-prepared PowerPoint presentation you can use to present your case for a new or revamped compliance programs to your CEO, complete with questions you should be prepared to answer.
Learn how to conduct a compliance investigation; understand the importance of having a formal investigations protocol in place; discuss the various roles in-house counsel may be called upon to play during a corporate crisis as a result of an investigation; and discuss FAQs and common lessons learned during compliance investigations.
Over the course of two sessions, learn how to structure and implement an effective compliance program; review hallmark DOJ guidance and discuss the Federal Sentencing Guidelines and their application to corporate compliance programs; learn how to conduct a gap analysis and design a compliance program that fits your organization’s needs; learn about successful program-building strategies and how to avoid compliance program pitfalls; and learn how to measure the effectiveness of your program and conduct a compliance audit.
Over the course of two sessions, learn how to structure and implement an effective compliance program; review hallmark DOJ guidance and discuss the Federal Sentencing Guidelines and their application to corporate compliance programs; learn how to conduct a gap analysis and design a compliance program that fits your organization’s needs; learn about successful program-building strategies and how to avoid compliance program pitfalls; and learn how to measure the effectiveness of your program and conduct a compliance audit.
The author considers why in-house lawyers see a distinct rise in urgent legal questions towards the late afternoon—just as the day is winding down to a close. Is it simple malice, a casual conspiracy, or something else entirely?