Who influenced defense industry suppliers to develop voluntary self-regulatory guidelines in
the 1970s and early 1980s? - ANSWER Inspector General June Gibbs Brown
What are the 7 safeguards for an effective compliance program? - ANSWER 1)
Demonstrates a commitment to good corporate conduct; 2) Can detect and prevent criminal
and unethical conduct; 3) Creates centralized source of info on industry regulations; 4)
Develops a methodology that encourages employees to report potential issues without fear
or retaliation; 5) Has procedures that allow for prompt, thorough investigation of alleged
misconduct; 6) Initiates immediate and appropriate corrective action; and 7) Reduces orgs
exposure to civil damages, criminal sanctions, and administrative remedies like program
exclusion.
What are the 4 aggravating factors to a culpability score? - ANSWER 1) Upper level
employee has participated in, condoned or was willfully ignorant of the offense; 2) Violation
is a repeat offense; 3) Government was hindered during its investigation; and 4) Pervasive
awareness of and tolerance of the violation
What are the 4 mitigating factors? - ANSWER 1) Orgs compliance program in effect
even though there was a violation; 2) Org reported violation promptly; 3) Org cooperated
with govt investigators; and 4) Org acted responsibly for violation
When did the Federal Sentencing Commission revise Chapter 8 in amendments? -
ANSWER In 2004 and 2010
What are the 7 basic compliance program elements? - ANSWER 1) Written standards
of conduct and P&Ps; 2) Compliance oversight via a CCO and other appropriate bodies; 3)
Effective education and training; 4) Audits and evaluation techniques to monitor compliance;
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the 1970s and early 1980s? - ANSWER Inspector General June Gibbs Brown
What are the 7 safeguards for an effective compliance program? - ANSWER 1)
Demonstrates a commitment to good corporate conduct; 2) Can detect and prevent criminal
and unethical conduct; 3) Creates centralized source of info on industry regulations; 4)
Develops a methodology that encourages employees to report potential issues without fear
or retaliation; 5) Has procedures that allow for prompt, thorough investigation of alleged
misconduct; 6) Initiates immediate and appropriate corrective action; and 7) Reduces orgs
exposure to civil damages, criminal sanctions, and administrative remedies like program
exclusion.
What are the 4 aggravating factors to a culpability score? - ANSWER 1) Upper level
employee has participated in, condoned or was willfully ignorant of the offense; 2) Violation
is a repeat offense; 3) Government was hindered during its investigation; and 4) Pervasive
awareness of and tolerance of the violation
What are the 4 mitigating factors? - ANSWER 1) Orgs compliance program in effect
even though there was a violation; 2) Org reported violation promptly; 3) Org cooperated
with govt investigators; and 4) Org acted responsibly for violation
When did the Federal Sentencing Commission revise Chapter 8 in amendments? -
ANSWER In 2004 and 2010
What are the 7 basic compliance program elements? - ANSWER 1) Written standards
of conduct and P&Ps; 2) Compliance oversight via a CCO and other appropriate bodies; 3)
Effective education and training; 4) Audits and evaluation techniques to monitor compliance;
1
