Risk Management

A good response plan will ensure that all team members have guidelines to follow. Whether government regulators inquire about business operations or potential fraud, everyone should know what steps to take. To protect both the business and the team members, corporate leaders should articulate the appropriate protocol any time an investigator makes an inquiry.

• Does everyone in your organization know how to respond in the event that an investigator asks a question?

Leaders can easily get an answer to that question by creating a plan. Then, they should create a training exercise for all team members. The more transparency leaders bring to an investigation-response plan, the more they will strengthen arguments that the organization has made a genuine effort to act in compliance with all regulations and laws.

Point for business leaders to consider:

• Regulators and judges are increasingly asking not just whether a company has an anti-fraud, anti-money laundering, or corporate ethics policy in place. They are also asking how well such programs work and whether their quality and results make sense. They are asking, in other words, how good are they? This trend raises the stakes for those charged with governance.

An example of an effective “anti-fraud policy” may prove helpful to business leaders that want to create an organizational-specific plan. Our suggestion follows: