Are you also a big fan of relevant and straightforward applicable tools? If so, then this practical example from one or our clients could support you during your daily work of managing risks.
The updated release of the DOJs “evaluation of Corporate Compliance Program” JM 9-28.800 can be seen as a great tool. In our last published article we started with the introduction of the DOJs release focusing on the overview. Now, we go into the details of the key risk areas.
The updated release of the DOJs “evaluation of Corporate Compliance Program” can be seen as a reminder. In a good way – because a lot of Corporate Compliance Program implementation goals are currently postponed due to the actual.
But only perfect for fraudsters and not for the individuals and the entire economy. The vulnerability of each is abused and does not yet have reached the peak. Being absorbed with the disaster itself leaves us putting fraud to the bottom of our priorities.
You know the experiment where one person starts with a sentence and whispers into the neighbour’s ear and the neighbour passes on what he has heard until this has passed through the circle of umpteen participants? What comes out?
While writing these paragraphs, we are in the middle (in my opinion rather at the beginning!) of the worldwide pandemic of COVID19. Countries are in different stages of their lockdown and the supporting measurements. The Economy is shot down and the economic price will be paid over the next decades.
Board of directors are not only responsible for overseeing management strategy, but also for their risks management which is significant in these fast-evolving times – especially under the actual circumstances of the global crisis. The Pharma industry works for a vaccination against COVID-19 and immunity tests. All great. For cyber-, non-compliance and fraud-risks there will never be a vaccination. Nor are we immune to these risks.
We humans open to manipulation. The higher the pressure – internal or external, the greater the diversity and the bigger the impact of the various biases. It would be naïve to believe that the current COVID-19 pandemic will not cause any damage in this respect.
Our vulnerability is more evident across the board than decades before. In recent years, it has only affected the “others”. Now it affects us all. The solution lies within human beings. As it usually does. Even an effective culture for enterprise-wide cyber security cannot be created with technology alone.
© 2023 Sonja Stirnimann
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