Chapter 10 Articles

Question 1

Keith Darcy pointed to several requirements issued by the U.S. government to operationalize and standardize corporate compliance programs including:

Answer 1

SEC: National Exam Program

DoJ:

• Foreign Corrupt Practices Act (FCPA) pilot program
• Evaluation of Corporate Compliance Programs

Question 2

Foreign Corrupt Practices Act (FCPA) Pilot Program

Answer 2

The pilot program assesses whether to provide credit to organizations that self-report potential FCPA violations and agree to cooperate with DoJ investigations.

Question 3

Making organizational changes to empower Chief Compliance Officers requires:

Answer 3

Strong leadership support that focuses on aligning the organization’s code-of-conduct values to the types of behaviors expected of management and the workforce - Mike Juergens

Question 4

Webcast question: Which do you think poses the biggest challenge to employee compliance in your organization’s global ethics program?

Answer 4

Inconsistency of clear, concise and frequent ethics program communications and training for all employees

Question 5

Since 2010, the SEC has received tips through the whistleblower program from how many countries?

Answer 5

103 countries

Question 6

A leading indicator of potential ethics violations

Answer 6

Found using well-crafted annual employee surveys

Question 7

Exit Interviews can be an effective tactic to address bribery, particularly true if

Answer 7

If the interviewer asks questions that prompt responses about issues stemming from the tone at the top

Question 8

Financial crime can be effectively addressed by:

Answer 8

Focusing on a “lifecycle” approach, rather than only reacting to a crisis

Question 9

Cottrell’s Four Drivers of Misconduct

Answer 9

1) Business models that focus solely on growth
2) Labor-intensive or convoluted processes around automation efforts
3) Inadequate monitoring/ surveillance
4) Weak Culture

Question 10

4 Challenges NGO’s may encounter

Answer 10

1) Prioritizing the speed of aid delivery over compliance
2) Multiple Compliance Requirements
3) Decentralized decision-making
4) Due diligence limitations

Question 11

COSO Fraud Risk Management Guide

Answer 11

Provides a framework of five fraud risk management principles

Question 12

Five Fraud Risk Management Principles

Answer 12

1) Selection
2) Development
3) Implementation
4) Monitoring of fraud preventative
5) Fraud detective control activities

Question 13

Investigation of fraudulent activity

Answer 13

Critical to initiate an investigation quickly to demonstrate to stakeholders that the organization is taking the allegations against it seriously

Question 14

A Successful Investigation is comprised of 4 things:

Answer 14

1) Maintenance of professional skepticism
2) Scoping the investigation carefully
3) Providing unfettered access
4) Documenting procedures, findings, and recommendations

Question 15

The UK’s Financial Reporting Council suggested changes to the rules is a new test that requires:

Answer 15

Auditing firms to consider whether future actions would affect their independence

Question 16

Canada’s ethics watchdog ruled that Prime Minister Justin Trudeau broke conflict-of-interest laws by:

Answer 16

Trying to steer the then-attorney general away from criminally prosecuting a Montreal company.

Question 17

Mr. Trudeau violated a section of Canada’s conflict-of-interests law that:

Answer 17

Prohibits public-office holders from using their posts to improperly further someone else’s private interests.