Compliance Program Development & Oversight Flashcards
7 cards from real CCCP practice questions. Tap to flip, then mark Knew It or Still Learning — missed cards come back until you master them.
Read the first 7 Compliance Program Development & Oversight flashcards as text
Which document typically establishes the compliance officer's authority, independence, and reporting lines within an organization?
Answer: The compliance program charter or mandate
The compliance program charter formally defines the CCO's authority, independence, access to information, and reporting relationships within the organization.
A company implements a new third-party due diligence process. Which risk is this control MOST directly designed to mitigate?
Answer: Bribery or misconduct by vendors, agents, or partners acting on behalf of the company
Third-party due diligence is specifically designed to assess and mitigate the risk that vendors, agents, or partners may expose the company to corruption or other compliance violations.
What is the key distinction between a compliance 'policy' and a compliance 'procedure'?
Answer: Policies state what must be done; procedures describe how to do it
A policy establishes the rule or standard (the 'what'), while a procedure provides the step-by-step instructions for implementing that rule (the 'how').
The DOJ's 'Evaluation of Corporate Compliance Programs' guidance (2020 updated) asks prosecutors to consider three 'fundamental questions.' Which is NOT one of them?
Answer: Does the program maximize shareholder returns?
The DOJ's three fundamental questions focus on program design, good-faith implementation, and practical effectiveness—not financial returns.
An organization's compliance hotline receives a report of potential financial fraud. Who should typically NOT be informed of the allegation during initial triage?
Answer: The subject of the allegation
The subject of the allegation should not be informed during initial triage to preserve the integrity of the investigation and prevent retaliation or evidence tampering.
Which principle underlies the concept of 'proportionality' in compliance program design?
Answer: The size and complexity of a compliance program should match the organization's specific risk profile
Proportionality means tailoring the compliance program's scope and resources to the organization's actual size, industry, geographic footprint, and specific risk exposures.
What is the primary compliance risk associated with 'tone at the middle' (managers and supervisors)?
Answer: If managers do not reinforce compliance values, employees may believe leadership messaging is hollow
Middle managers translate organizational culture into daily behavior; if they undermine or ignore compliance messaging, employees learn that compliance is not truly valued.