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.
Toby Duthie, Founding Partner