Arethe Chief Compliance Officer of a Fortune 500 company. Through a routine compliance audit, you have discovered
Question:
Arethe Chief Compliance Officer of a Fortune 500 company. Through a routine compliance audit, you have discovered potential illegal activity within one of the corporate divisions. Youhave advised the General Counselof this matter and she has, in turn, retained an external law firm to conduct an investigation. Based upon the findings of this investigation, the General Counsel has advised the Board of Directors that violations of civil and criminal law have been substantiated and the matter must be reported to the relevant government agencies.
The Directors appear to be disregarding that advice and you have requested a meeting with them to convey your positions on this matter as the Chief Compliance Officer.
Referencing the reading materials from the course, prepare a PowerPoint presentation that addresses the following:
- The ramifications for the organization's failure to disclose the violations of law, including summaries or case examples of companies that were found to have withheld information from the government regarding illegal activity and/or compliance failures.
- The benefits to the organization if it proactively self-discloses the illegal conduct.
- The Board's liability for failing to disclose the illegal conduct.
- The next steps that you may take as the Chief Compliance Officer, individually and on behalf of the organization, if the Board refuses to self-report.