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Board and Fraud is a blog that aims to bring a practical approach to issues facing the board of directors and the audit committee specifically in the area of governance, risk management, compliance, and internal audit, with a strong focus on fraud, ethics, and internal controls.

Fraud and Compliance Master Class in Chicago, Illinois on March 20 and 21, 2019

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Baker Tilly

Register here!

Announcing the next offering of the Doing Compliance Master Class. Tom Fox is partnering with Jonathan T. Marks from Baker Tilly Virchow Krause, LLP, to put on a two-day class that is unlike any other currently being offered. It will be held in the Baker Tilly Downtown Chicago Offices 205 North Michigan Ave #2800, Chicago, IL 60601, on March 20 and 21, 2019.

The class is not just theory or analytical underpinnings of the Foreign Corrupt Practices Act (FCPA) but focuses on the operationalizing of compliance. For it is only in the doing of compliance that companies have a real chance of avoiding FCPA liability.

Jonathan T. Marks, a Partner at Baker Tilly and well-known for his knowledge on governance, conducting global (cross-border) investigations (including FCPA), designing and enhancing internal controls, evaluating compliance/internal programs, and conducting root cause analysis , will also join me.

The Master Class provides a unique opportunity for any level of FCPA compliance practitioner, from the seasoned Chief Compliance Officer (CCO) and Chief Audit Executive (CAE), Chief Legal Counsel (CLO), to the practitioner who is new to the audit or compliance professions.

If you are looking for a training class to turbocharge your knowledge on the nuts and bolts of a best practices compliance program going forward, this is the class for you to attend. Moreover, as I limit the class to 20 attendees, you will have an intensive focus group of like-minded compliance practitioners with which you can share best practices. It allows us to tailor the discussion to your needs. Mary Shirley, an attendee at the recent Boston Master Class said, “This is a great two day course for getting new folks up to speed on what matters in Compliance programs.”

Tom and Jonathan are leading commentators and thought leaders in the compliance space, plan on bringing unique insight of what many companies have done right and many have done not so well over the years. This professional experience has enabled us to put together a unique educational opportunity for any person interested in compliance. Simply stated, there is no other compliance training on the market quite like it.

Armed with this information, at the conclusion of the Doing Compliance Master Class, you will be able to implement or enhance your compliance program, with many ideas at little or no cost.

The Doing Compliance Master Class will move from theory to practice. We show you how you must document this work to create a best practices compliance program.

Building from the Ten Hallmarks of an Effective Compliance, using the questions posed from the Evaluation of Corporate Compliance Programs and the FCPA Corporate Enforcement Policy as a guide, you will learn the intricacies of risk assessments; what should be included in your policies and procedures; the five-step life cycle of third party risk evaluation and management; tone throughout your organization; training and using other corporate functions to facilitate cost-effective compliance programs.

Highlights of the training include:

  • Understanding the underlying legal basis for the law, what is required for a violation and how that information should be baked into your compliance program;
  • What are the best practices of an effective compliance program;
  • Why internal controls are the compliance practitioners best friend;
  • How you can use transaction monitoring to not only make your compliance program more robust but as a self-funding mechanism;
  • Your ethical requirements as a compliance practitioner;
  • How to document what you have accomplished;
  • Risk assessments – what they are and how you can perform one each year.

You will be able to walk away from the class with a clear understanding of what anti-corruption compliance is and what it requires; an overview of international corruption initiatives and how they all relate to FCPA compliance; how to deal with third parties, from initial introduction through contracting and managing the relationship, what should be included in your gifts, travel, entertainment (GTE) and hospitality policies; the conundrum of facilitation payments; charitable donations and political contributions, and trends in compliance. You will also learn about the importance of internal controls and how to meet the strict liability burden present around this requirement of FCPA compliance.

The Doing Compliance Master Class will be based around Tom’s latest publication, The Compliance Handbook, released in May 2018.

The Handbook was No. 1 in Amazon’s Business Ethic’s category when released and it focuses on the creation, implementation and enhancement of a best practices compliance program.

Classes start promptly at 8:30 am.

Draft Agenda is below:


8:30 – 9:00 Coffee, Registration & Breakfast

9:00 – 9:30 Welcome and Introduction

Course Objectives and Overview

9:30 – 10:30 Master Class-Doing Compliance Enforcement Review

Global Anti-Corruption Enforcement Trends

10:30 – 10:45 Snack Break

10:45 – 12:00 Effective Anti-Corruption Ethics and Compliance Program

Benefits of Ethics and Compliance Program

Anti-Corruption Compliance Program Requirements

12:00 – 1:00 Networking Lunch

1:00 – 2:00 Risk Assessments

Purpose of Risk Assessment

Types of Risk Assessments

Continuous Risk Assessment Strategies

Tailoring Compliance Program to Risk Assessment

2:00 – 2:15 Snack Break

2:15 – 3:15 Due Diligence

Risk-Based Third-Party Risk Management System

Joint Venture Partners

Mergers and Acquisitions

3:15 – 3:30 Snack Break

3:30– 4:30 The Regulators View of the Importance of an Ethical Culture

Building, Maintaining and Measuring Culture


8:00 – 8:30 Coffee & Breakfast

8:30 – 10:00 Root Cause Analysis and Internal Investigations

How a Root Cause Analysis Differs from an Investigation

Types of Investigations

Privilege, Documents and Interviews


10:00 – 10:30 Legal Ethics for the Compliance Practitioners

What is a lawyer’s duty?

Legal Obligations-Miranda and Upjohn



10:30 – 10:45 Snack Break

10:45 – 12:00 Internal Controls

What are Internal Controls?

Internal Control Enforcement

Mapping of Internal Controls to Compliance Program

COSO 2013 Internal Controls Framework and COSO 2017 ERM Framework

12:00 – 1:00 Networking Lunch

1:00 – 2:00 Gifts, Meals, Entertainment and Travel


Procedures for Review

Safe Harbor

2:00 – 3:00 Compliance Problems and Discussion

Interactive Case Discussions

Practical Problems from Enforcement Actions

Wrap Up and Summary

A Certificate of Completion will be provided to all who attend in addition to the continuing education that is approved.

Breakfast, lunch and refreshments will be provided both days. Registration information will be provided soon!


CPE Credits – 16 hours

NASBA – Baker Tilly is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.learningmarket.org. 

Refund Policy

Our refund policy is that you have five (5) business days from the completion of the course to request a refund. All refund requests must be in writing and directed to tfox@tfoxlaw.com.

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