Compliance & Ethics Program Administration Flashcards

What is the PRIMARY purpose of a compliance program gap analysis?

Answer: To identify discrepancies between current program elements and best practices or regulatory requirements

A gap analysis identifies where current compliance program elements fall short of required or recommended standards, guiding remediation priorities.

Which factor MOST significantly affects the credibility of an internal compliance investigation?

Answer: Objectivity and independence of the investigators

Investigator objectivity and independence are fundamental to producing credible, unbiased findings that withstand internal and external scrutiny.

Under the DOJ's Evaluation of Corporate Compliance Programs guidance, which factor is evaluated to determine if a compliance program is 'adequately resourced'?

Answer: Whether compliance has sufficient staff, authority, and tools to perform its mandate

The DOJ assesses whether the compliance function has adequate personnel, budget, and authority to effectively execute its responsibilities.

An organization wants to assess whether its code of conduct is actually influencing employee behavior. The BEST approach is to:

Answer: Survey employees on code awareness and observed behaviors

Surveys measuring both awareness and observed behaviors provide insight into whether the code of conduct is translating into actual employee conduct.

Which best describes the concept of 'tone at the top' in a compliance and ethics program?

Answer: Senior leadership's public and private commitment to ethical behavior and compliance

Tone at the top refers to the genuine commitment senior leaders demonstrate through their words, decisions, and actions toward ethics and compliance.

A compliance officer is developing a new third-party due diligence program. Which step should come FIRST in the process?

Answer: Risk-tiering third parties based on relationship type and exposure

Risk-tiering allows the organization to allocate due diligence resources proportionally, applying greater scrutiny to higher-risk third-party relationships.

Which of the following BEST describes the role of the compliance committee in a large organization?

Answer: To coordinate compliance activities across business units and escalate systemic issues

Compliance committees provide cross-functional coordination, ensure consistent policy application, and surface systemic issues requiring senior attention.