How To Implement Compliance Risk Management, Compliance Audits, Root Cause Analysis, and DOJ Self Reporting
Recorded On: 10/07/2024
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The Department of Justice’s Guidelines on Effective Compliance Programs draw a clear connection between an organization’s risk management and compliance programs. The effectiveness of an organization’s risk management program can determine the effectiveness of its compliance program. This panel session will provide a comprehensive perspective on the importance of risk management in compliance, how to use it in audits and root cause analysis, and the pros and cons of self-reporting.
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Barbara Barrett
Chief Compliance Officer
Reliant Care Management Company
Accomplished Attorney with a strong background in health care, litigation and corporate compliance. Skilled litigation attorney with extensive experience in professional liability cases as well as large complex commercial litigation. Successfully resolved government investigations with State Attorney Generals and U.S. Attorneys. Experience in managing outside counsel and setting litigation strategy. Expertise in drafting corporate compliance programs and conducting compliance investigations. Experience in developing and conducting training on legal and compliance matters.
Specialties: attorney, litigation, corporate, billing systems, compliance, antitrust, fraud, health care, false claims act, drafting, insurance, law enforcement, legal, litigation, negotiation, presentation skills, risk management, class action, in-house counsel,
Rachel Hirsch
Chief Legal Counsel
American Israel Public Affairs Committee
Courtney Brown
Partner
Gibson Dunn
Courtney M. Brown is a partner in the Washington, D.C. office of Gibson, Dunn & Crutcher, where she practices primarily in the areas of white collar criminal defense and corporate compliance. Courtney has experience representing and advising multinational corporate clients, boards of directors, and executives in internal and government investigations and enforcement actions on a wide range of topics, including anti-corruption, anti-money laundering, economic sanctions, financial and accounting, and tax fraud matters.
Courtney has been recognized as a leading lawyer by Chambers USA in the District of Columbia for Litigation: White-Collar Crime & Government Investigations. She was also recognized in The Best Lawyers in America® guides for work on Criminal Defense: White-Collar matters in 2025 and 2024.
Courtney also counsels corporations on the effectiveness of their compliance programs and in connection with transactional due diligence, with a particular emphasis on compliance with anti-corruption laws, anti-money laundering regulations, and economic and trade sanctions administered by the U.S. Department of Treasury’s Office of Foreign Assets Control.
Selected investigation and enforcement matters include:
- Represented a multinational information technology company in negotiating resolutions of claims brought by the U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) under the U.S. Foreign Corrupt Practices Act (“FCPA”), including successful completion of a post-resolution reporting period.
- Represented a global telecommunications company in a resolution with DOJ regarding non-criminal breaches of a Deferred Prosecution Agreement.
- Represented a financial services firm in negotiating a declination under DOJ’s Corporate Enforcement Policy.
- Conducted an investigation for the Board of Directors involving allegations of insider dealing against executives.
- Representing a Special Litigation Committee of the Board of Directors of a pharmaceutical wholesale distribution and service provider in shareholder derivative litigation regarding Board oversight of the company’s compliance program.
- Conducted a workplace investigation on behalf of a Special Committee of the Board of Directors.
- Represented an investment manager in an SEC investigation involving allegations of false advertising and securities regulations violations.
- Represented a defense company, obtaining declinations of criminal and civil enforcement actions by the DOJ and SEC in FCPA investigations, as well as the dismissal of an employment lawsuit brought by a former employee.
- Obtained declinations, on behalf of a Fortune 500 company, of criminal and civil enforcement actions by the DOJ and SEC in a joint FCPA investigation arising from whistleblower complaints.
- Represented banks and asset managers in investigations by the DOJ, SEC, congressional committees, and state investigators relating to subprime mortgage matters and the Madoff fraud.
Courtney has participated in two government-mandated FCPA compliance monitorships and conducted anti-corruption and compliance trainings for in-house counsel and employees. Courtney also completed a secondment at a Fortune 100 company, where she advised global legal and business teams on compliance with anti-corruption laws.
Courtney received her law degree in 2008 from the University of Chicago Law School. Prior to law school, she worked for the Chairman of the U.S. Senate Health, Education, Labor and Pensions Committee. Courtney earned her undergraduate degree from Harvard University, where she was co-captain of the NCAA Division I championship women’s crew team and an All-American selection in rowing. Courtney is a member of the bars of the District of Columbia and Virginia.
CLE/CPD CREDIT IS AVAILABLE IN THE FOLLOWING JURISDICTIONS:
*Alaska, *Arizona, California, *Connecticut, Georgia, *Hawaii, Illinois, Minnesota, *Montana, *New Hampshire, *New Jersey, *New York, *North Dakota, Ohio, Pennsylvania, Tennessee, Texas, and Washington.
*Indicates that CLE/CPD credit is available by virtue of reciprocity with another jurisdiction.
ATTENDEES MUST SELF-FILE IN THE FOLLOWING JURISDICTIONS (A CERTIFICATE WILL BE PROVIDED TO ASSIST YOUR FILING EFFORTS):
Alabama, Arkansas, Colorado, Delaware, Florida, Idaho, Indiana, Iowa, Louisiana, Kansas, Kentucky, Maine, Mississippi, Missouri, Nebraska, Nevada, New Mexico, North Carolina, Oklahoma, Oregon, Puerto Rico, Rhode Island, South Carolina, Utah, Vermont, West Virginia, Wisconsin, and Wyoming.
CLE/CPD IS NOT MANDATORY IN THE FOLLOWING JURISDICTIONS:
District of Columbia, Maryland, Massachusetts, Michigan, South Dakota
