1. Prepare Sample Interview Questions for
Best Practice/Gap
analysis   (think about who you gonna interview, what do you want to ask, why? the questions should include all areas such as security, risk, etc) who you gonna interview: can be sales people, advertising, marketing department, or outside ad agency.
 
2. Prepare a Risk Assessment-FCPA Compliance (should include
4 steps of Risk Assessment:
Inventory documents; Interview question; Heat map dashboard: include the risk; Executive summarize
)
 
 
Conducting a High Level Compliance Risk Assessment
 During Phase I, you should:
·
    
Form a committee;
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Interview key officers and employees;
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Prepare a report on Risk Assessment, including Best Practices and Gaps; and
·
    
Present the report on Risk Assessment, including Best Practices and Gaps.
·
    
The Committee should be composed of at least the following:
·
                    
CEO or President
·
                    
General Counsel
·
                    
CFO
·
                    
Internal Audit Director
 
The Committee should report to the Audit Committee of the Board of Directors or directly to the Board of Directors
 
Interview key officers and employees of the company and all subsidiaries including the following:
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President,
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Business Development/Sales Marketing,
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General Counsel/Outside Counsel,
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Chief Financial Officer,
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Human Resources Director,
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Environmental Health and Safety, if any,
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Compliance Officer, if any, and
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Other key officers and employees, as necessary
 
Based on the interviews, prepare a report on Risk Assessment, including Best Practices and Areas of Deficiency (gaps) based on the following questions:
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What are your key risk areas?
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What are the standards and procedures that you now have in place in these risk areas?
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What are the areas you have successfully limited risk and how?
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What areas could you improve in the cost to limit risk and how?
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What is happening in such key areas as antitrust, environmental, employment, intellectual property and insider trading?
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Describe the company culture toward corporate compliance and limiting risk.
 
Present the report on Risk Assessment, including Best Practices and Gaps:
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The report should provide a risk assessment for relevant areas of law.
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The report should be presented to senior management and the Board of Directors.
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The report should be presented to the officers of all subsidiaries who were interviewed.
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Buy-in on the report should be encouraged.
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Create a Workplan which includes a timetable and an action plan.