Did you know that failure to act even without intent of wrongdoing, is now enough to warrant prosecution of a Chief Compliance Officer? Did you know that one of three violations specified by the SEC in a case involving a Chief Compliance Officer was failure to conduct an annual review of its compliance program? Did you know another Chief Compliance Officer was fined $60,000, personally, in part for failure to recommend written policies and procedures to support an existing Conflict of Interest Policy? What else do you need to know? To find out, join this webinar: The DOJ Gets Personal: 6 Things You Should Know About the Yates Memo.
Objectives of the Presentation:
- Current DOJ thinking about personality liability for corporate wrong-doing
- What is replacing the "Deep Pockets" mentality
- The six most important points in the Yates Memo
- New Risks for Chief Compliance Officers
- The Demise of Ceresney Standard: SEC Enforcement and the role of Intent in Acts of Omission and Commission
- Recent case history involving prosecution of corporate compliance officers as individuals
- What you can do to protect yourself and your organization
- In addition, participants will take away an educational infographic that visually highlights the 6 key points of the Yates Memo that compliance officers and other C-suite executives should know
- Overview of advisory landscape
- Why the Yates Memo is a game-changer
- The Yates Memo: 6 things you should know
- What would you do for co-operation credit?
- Timing issues. Who is looking at what when?
- Criminal and civil attorneys - "Can we talk?"
- Going it alone: no more riding on coattails
- Running out the clock won't work either
- "Deep pockets" don't matter anymore
- Sins of omission not just commission
- Case Study: BlackRock
- Case Study: SFX
- Late breaking case study/news
- Your next move: protecting yourself and your organization
Who Will Benefit:This 60-minute overview will be of value to Corporate Compliance Officers and Other C-Suite Executives. The course will benefit the following stakeholders:
- All Corporate Officers subject to SEC and/or DOJ Enforcement
- Chief Compliance Officers
- Privacy and Security Officers
- Chief Executive Officers
- Chief Financial Officers
- Revenue Cycle Executives
- In-house Counsel
Harriett combines more than 25 years of health industry experience and her knowledge of payment reform to deliver solutions that work for LWCI clients. Her experience includes serving providers, payers, and vendors. She has expertise in payment reform, compliance, revenue cycle, Medicare policy and payment; clinical documentation improvement; and operations improvement. She has worked across the spectrum of healthcare providers including hospitals and health systems; inpatient rehabilitation hospitals and units; critical access hospitals; physician practices; ambulatory care; hospice and skilled nursing facilities.
As an accomplished leader, she has led Board of Directors-sponsored corporate compliance engagement to revise and promote a new Code of Conduct for one of the country's largest health plans. She has led numerous compliance engagements including clinical documentation improvement projects, compliance audits as well as strategy engagements. Harriett is notable for her ability to create effective business development strategy and tactics for healthcare providers, payers and vendors.
Harriett holds an MBA from Harvard Business School and a B.S. degree in Physical Therapy from Northeastern University. She has been a speaker for healthcare professional organizations in the U.S. and Australia. She is a member of Health Care Compliance Association (HCCA), Healthcare Financial Management Association, American Health Lawyers Association (AHLA) AHLA and American Medical Rehabilitation Providers Association (AMRPA).