Does Your Risk Assessment Meet Legal Muster?

3/15/16:  In the March 2015 issue of Compliance and Ethics Professional (the publication of the Society of Corporate Compliance and Ethics), an article by Jeffrey M. Kaplan argues that not all corporate compliance programs “… are up to legal ‘snuff’ when it comes to risk assessment.”  How can that be?  Risk assessments are part of virtually all compliance programs.  The problem is that many companies do not use their risk assessments in ways that comply with the Federal Sentencing Guidelines for Organizations’ requirement that they “design, implement, or modify each requirement…” of an effective compliance program to reduce risks identified through the assessment.  Kaplan’s short article highlights ways in which some companies fall short and what they can do about it.