Fleet-Footed Investigations and Prompt Remedial Action: The New Normal

Does your company respond to all internal concerns immediately, investigate them thoroughly and remediate them with unmatchable speed? What if the concern comes from an officer, director, lawyer, compliance professional, internal auditor, or an outside accountant? Do you assume you have time because, after all, it is the informant's "job" to identify and remedy non-compliance? Or do you jump on the concern regardless of who raises it, launching and concluding your investigation and implementing remedial action within 120 days? The Security and Exchange Commission's recent Dodd-Frank bounty award of half a million dollars to a former company officer who waited the requisite 120-day period tells companies they must act immediately no matter who raises or learns of the concern.



http://ift.tt/1zJhkYu