Fcpa Compliance Report

I end my One Month to a Better Board series with a discussion from the recently released Justice Department Evaluation of Corporate Compliance Programs as it relates to a Board of Directors. In an area of inquiry entitled, “Oversight” the DOJ asked three basic questions which we have explored throughout this series. The questions presented by the DOJ were: What compliance expertise has been available on the board of directors? Have the board of directors held executive or private sessions with the compliance function? What types of information has the board of directors examined in their exercise of oversight in the area in which the misconduct occurred? In addition to specifically stating that a Board of Directors must have a compliance subject matter expert going forward, it opines there should be a Board level committee dedicated to compliance as well. I have previously explored questions a Board should ask a Chief Compliance Officer (CCO). Today I want to focus some attention on questions by a Board of