Toby Duthie speaking at the Global Forum on Corporate Criminal Liability

One of FRA's Founding Partners, Toby Duthie, spoke at the Global Forum on Corporate Criminal Liability in Germany, on 16 March. Toby spoke on the anatomy of a healthy compliance program alongside Elizabeth Radigan from Diebold Nixdorf.

They used US and international regulators' guidance documents to draw on vast in-house and external counsel experience. Toby and Elizabeth explored the details of what makes a good compliance program run effectively whilst allowing the business to grow and what will stand up to government scrutiny.

Toby's key take-aways from the conference:

• Cyber and data privacy is at the forefront of everyone's mind and this was before the Cambridge Analytica blow up;
• Individual rights versus corporate cooperation;
• Massive uptick in enforcement and issues around double jeopardy growing exponentially;
• Prevention is better than cure and the need for transactional testing in any compliance and remediation efforts - enforcement authorities expect this; and
• Culture, culture, culture - tone and the top and tone in the middle to drive change.