“Do we need to invest in an anti-corruption program?” & Three Questions with Douglas Veivia

Should we be investing in an anti-corruption program? Anti-corruption risk is a “high severity/low likelihood” risk for nearly all organizations.  But, if it does happen it can be very serious.  Eric will look at data between the Department of Justice and various corporate defendants. If you are asking, “Should we be investing in an anti-corruption program?” it’s probably not the question you should be asking. There are more important questions– “What are the compliance risks for this organization?” “Have you done a compliance risk assessment? “Have you evaluated what risks you face as an organization?” “How have you done that and how recently?” “How comfortable are you with that risk assessment? You also have to ask before you get to a more specific question about anti-corruption is “What are we doing about those risks?” “What is in-place to address those risks at this point?” The Upshot While anti-corruption is a very serious risk it is one with very low likelihood for many organizations. Every organization needs to understand their own particular risks. By doing that you will know if you need to have an anti-corruption program. Three Questions with Douglas Veivia, VP, International Compliance at Prudential Financial Inc. If you a question you want answered on the podcast be sure to submit it on ComplianceBeat.com or reach out below.  https://twitter.com/eric_morehead LinkedIn -Eric Morehead https://www.facebook.com/compliancebeat/ Read Full Transcript Should we be investing in an anti-corruption program? Anti-corruption risk is a “high severity/low likelihood” risk for nearly all organizations. This means that if it happens it can be very serious, can impact the company for many years, cost millions of dollars, and may mean that individual employees spend time in federal prison. This is very high severity. Low likelihood risk means that the actual overall risk is not as “highly likely” as is often perceived by the compliance community-at-large. Looking at enforcement numbers from 2015, the last full year of available data, there were 100 non-prosecution (NPA) and deferred prosecution (DPA) settlements entered between the Department of Justice and various corporate defendants. For those of you who understand anti-corruption, or the Foreign Corrupt Practices Act (FCPA), you already know that NPA and DPA agreements are the mechanism by which the Department of Justice and defendants can settle a potential criminal case without it ever being filed, or by deferring the case for a period of time until the company can complete the terms-of-agreements made in the settlement. These NPAs and DPAs have