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What is a root cause analysis?

Tom Fox | January 23, 2018

One new and different item was laid out in the Evaluation of Corporate Compliance Program, supplementing the Ten Hallmarks of an Effective Compliance Program from the 2012 FCPA Guidance. This was the performance of a root cause analysis for any compliance violation that may led to a self-disclosure or enforcement action. Under Prong 1 Analysis and Remediation of Underlying Misconduct, the Evaluation stated:

 Root Cause Analysis What is the company’s root cause analysis of the misconduct at issue? What systemic issues were identified? Who in the company was involved in making the analysis? 

Prior Indications Were there prior opportunities to detect the misconduct in question, such as audit reports identifying relevant control failures or allegations, complaints, or investigations involving similar issues? What is the company’s analysis of why such opportunities were missed? 

The new Department of Justice (...

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