1. Analysis and Remediation of Underlying Misconduct

Root Cause Analysis – What is the company’s root cause analysis of the misconduct at issue? What systemic issues were identified? Who in the company was involved in making the analysis? 

A root cause analysis should be a method to learn more about your business process and what went wrong so that the systems and process itself can be changed because there is a thinking in the field which basically centers around the theme of, unless you have changed the process, then you're going to keep getting similar or the same results. The process is going to deliver whatever it delivers, whether that be right, wrong, or indifferent. Until you change the process and the systems, you can basically expect that you're going to have some sort of output that is going to repeat itself over and over again. Finding blame does not necessarily help and really you want to get deeper into those root causes. The reason it is monikered “root cause analysis”, is to emphasize the need to drill down below the superficial pieces of the framework to fix, and into the things that are actually driving the outcomes and the behaviors.

Three Key Takeaways

1. The DOJ Evaluation mandates a root cause analysis.
2. You cannot have a culture of blame for a root cause analysis to be effective.
3. Always remember CAPA.

This month’s podcast series is sponsored by Oversight Systems, Inc. Oversight’s automated transaction monitoring solution, Insights On Demand for FCPA, operationalizes your compliance program. For more information, go to OversightSystems.com.

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