Compliance and Ethics Program Administration

Question 1

Legal vs. Compliance

Answer 1

Legal defines and advises on the law
Provides Legal Advice and Analysis
* Attorney-Client Privilege
* Sensitive Investigations
* Voluntary Disclosure to Regulators
* Criminal Penalties or Litigation
* Protects Against Legal Risk

“Develops controls, policies, procedures, and systems”
* Advises on Policies, Procedures & Processes
* Puts Controls in Place
* Routine Investigations, Auditing and Monitoring
* Fosters an Ethical Culture

Question 2

Background Checks?

Answer 2

• Background checks and screenings must be conducted (e.g., new hires, substantial authority personnel, third parties, government lists)
• List of Excluded Individuals/Entities (LEIE) (OIG)
• OFAC Specially Designated Nationals And Blocked Persons List (SDN)

Question 3

Credibility and integrity

Answer 3

How would you demonstrate credibility and integrity of the compliance program?
* Discipline policy is applied regardless of rank (e.g. if a senior executive does
something illegal, are they disciplined according to policy?)