FCPA (Foreign Corrupt Practices Act)
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Forbids bribery
,Fed sentencing guidelines INCREASES fines when:
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Death results, if there is any gain that is not paid back in the restitution,
Threat of/Foreseeable Threat of Bodily Harm, Threat to National Security,
Threat to Environment, Threat to a Market, Official Corruption, If the
Organization is/was a Public Entity,
Who does a Compliance Officer report to?
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A board of directors, or audit committee
Discipline must be
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proportionate to violation and consistent across the organization
CO does what in regards to corrective action plans?
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, Monitors effectiveness of corrective action plans
Audits from External Entities should be...
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Addressed
Rules of Conduct: R1.3 CEPS shall exercise
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CEPS shall exercise sound judgment in responding to and cooperating
with all official and legitimate government investigations/inquiries: Never
obstruct or lie
Compliance and Ethics related risks must be....
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Audited and Monitored
Rules of Conduct: R2.1 CEPs shall serve their employing organizations in a....
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, timely, competent, and professional manner.
Fed sentencing guidelines defines "High Level personnel" as
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Individuals who have substantial control over the organization or have a
substantial role in making policy for the organization
HIPPA (Health Insurance Portability and Accountability Act)
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Protects individual health information
Rules of Conduct: R2.4 CEPs shall keep...
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Senior Management and the highest governing body informed of the
status of the compliance and ethics program, both as the implementation
of the program and about areas of compliance risk.
Elements of CEP Code of Ethics: Principle III: Obligations to the Profession
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Forbids bribery
,Fed sentencing guidelines INCREASES fines when:
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Death results, if there is any gain that is not paid back in the restitution,
Threat of/Foreseeable Threat of Bodily Harm, Threat to National Security,
Threat to Environment, Threat to a Market, Official Corruption, If the
Organization is/was a Public Entity,
Who does a Compliance Officer report to?
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A board of directors, or audit committee
Discipline must be
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proportionate to violation and consistent across the organization
CO does what in regards to corrective action plans?
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, Monitors effectiveness of corrective action plans
Audits from External Entities should be...
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Addressed
Rules of Conduct: R1.3 CEPS shall exercise
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CEPS shall exercise sound judgment in responding to and cooperating
with all official and legitimate government investigations/inquiries: Never
obstruct or lie
Compliance and Ethics related risks must be....
Give this one a try later!
Audited and Monitored
Rules of Conduct: R2.1 CEPs shall serve their employing organizations in a....
Give this one a try later!
, timely, competent, and professional manner.
Fed sentencing guidelines defines "High Level personnel" as
Give this one a try later!
Individuals who have substantial control over the organization or have a
substantial role in making policy for the organization
HIPPA (Health Insurance Portability and Accountability Act)
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Protects individual health information
Rules of Conduct: R2.4 CEPs shall keep...
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Senior Management and the highest governing body informed of the
status of the compliance and ethics program, both as the implementation
of the program and about areas of compliance risk.
Elements of CEP Code of Ethics: Principle III: Obligations to the Profession
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