Effective Compliance Programs Coursera Quiz Answers

All Weeks Effective Compliance Programs Coursera Quiz Answers

Effective Compliance Programs Week 1 Quiz Answers

Quiz 1: The Role of the Compliance Officer

Q1. True or False: Highly regulated companies are legally required to hire Chief Compliance Officers.

• True
• False

Q2. True or False: An organization may suffer from a compliance program that is too robust.

• True
• False

Q1. How has the role of the chief compliance officer (CCO) changed over time? (Hint: There are 2 correct answers).

• CCOs are increasingly expected to act not as niche specialists, but as top level advisors who understand a company’s business needs.
• CCOs are focusing less on high level compliance in favor of more department-specific compliance.
• CCOs are focusing more on legal issues than ever before.
• It is more important than ever for CCOs to possess strong interpersonal skills, like listening and problem solving.

Q2. Which options help CCOs promote compliance within an organization? (Hint: There are 3 correct answers).

• Avoiding conflicts of interest
• Fostering psychological safety in the workplace
• Ensuring that every employee feels a personal responsibility for complying with relevant rules and regulations
• Ensuring that every employee recognizes and accepts the company’s compliance program

Q3. Which of the following is NOT an element codified in the Federal Sentencing Guidelines for building an effective compliance and ethics program?

• An effective training and awareness program
• Exclusion of individuals known, through due diligence, to be engaged in illegal activities or other compliance or ethics-related misconduct
• Consistent enforcement through discipline
• All of the above are codified in the FSG

Q4. Which of the following are true statements about compliance? (Hint: There are 2 correct answers).

• CCOs should conduct risk assessments before crafting risk management policies and procedures.
• CCOs should integrate themselves with and report to business units that face particular compliance challenges.
• To avoid confusion, CCOs should report to a singular person or entity, whether it be the CEO or a compliance committee.
• Tolerating employee misconduct threatens a company’s attempt to create a “tone at the top” that is conducive to compliance.

Effective Compliance Programs Week 2 Quiz Answers

Quiz 1: The Code of Ethics

Q1. The SEC rules list several goals that a code of ethics should achieve. Which of the following is NOT one of them?

• Compliance with applicable governmental laws, rules and regulations
• Accountability for adherence to the code
• Full, fair, accurate, timely and understandable disclosure
• Efficiency in company operations

Q2. What should a CCO aim to achieve in promulgating a code of ethics? (Hint: There are 2 correct answers).

• To convey what is permitted and prohibited on a daily basis
• To create the illusion of compliance
• To ensure that employees have easily digestible ethical guidelines accessible to them at all times
• To create a document that will be referenced by both senior management and lower level employees

Q1. True or False: The goal of a strong compliance program is to minimize the number of reports of misconduct.

• True
• False

Q2. True or False: It is important that the CCO inform executive leadership about all compliance incidents.

• True
• False

Q3. In some situations, it might make sense for a company to hire a vendor that has struggled with compliance in the past.

• True
• False

Q1. Which of the following constitute best practices for CCOs adopting policies and procedures in the workplace? (Hint: There are 2 correct answers).

• Ensure that polices are circulated and reviewed by different departments before being formally adopted.
• Share customer information only with vendors that have not experienced compliance failures in the past.
• When training employees, acknowledge that everyone has a different view of what compliance means.
• Ensure that the public knows where it can report ethical violations or compliance failures.

Q2. Federal law imposes penalties on financial institutions for failing to: (Hint: There are 2 correct answers).

• Comply with Pay-to-Play laws prohibiting certain campaign contributions
• Monitor employees’ emails on a regular basis
• Monitor which employees have access to restricted floors, offices, or data rooms
• Review and report on the personal securities transactions of certain employees.

Q3. True or False: Federal law requires every company to conduct and file audited financial statements annually.

• True
• False

Q4. A CCO notices that, for the fifth week in a row, a certain employee has submitted a receipt for an unusual amount. What steps would be appropriate for the CCO take in response? (Hint: There are 2 correct answers).

• Notify a senior executive that there has been a compliance breach.
• Explore further to determine the reason for the anomalous receipts.
• Discipline the employee in accordance with the company’s Code of Conduct.
• Send an email to all employees reminding them of the company’s spending and reimbursement policy.

Q5. W​hich of the following is not true about monitoring employees’ emails?

• I​t can prevent potential problems from maturing into real problems.
• I​t is required in most industries.
• I​t can give the compliance department a good idea of what is going on at the company.
• I​t enforces good email practices.

Q6. A Code of Conduct: (Hint: There are 2 correct answers).

• i​s an aspirational rather than practical document.
• S​ets the tone for the way employees are supposed to act.
• Should be the bedrock of a compliance program.
• i​s mandatory for companies to establish in most industries.

Effective Compliance Programs Week 3 Quiz Answers

Quiz 1: Theories of White Collar Crime

Q1. Which theory of white collar crime best matches the following quote?

“Mr. Madoff’s crimes were extraordinarily evil.” –Judge Denny Chin

• The Lack of Self-Control Theory
• The No Harm Theory
• The Psychological Aberration or Deviation Theory
• The “Everyone is Doing It” or “Virus” Theory

Q2. Which theory of white collar crime best matches the following quote?

“Some call it gratuities, some call them able payments, some call it extortion . . . I looked at these payments as necessary to sell a product.” –Carl Kotchain

• The Lack of Recognition Theory
• The Privileged or Entitled Theory
• The Lack of Self Control Theory
• The No Harm Theory

Q3. Which theory of white collar crime best matches the following quote?

KPMG partner Scott London recalled thinking, “I really should not be doing this,” but he did it anyway.

• The Psychological Aberration or Deviation Theory
• The “Cost-Benefit / Risk-Reward” Theory
• The Privileged or Entitled Theory
• The Lack of Self-Control Theory

Q1. Over the past few months, Company X has struggled with employees regularly violating compliance rules. What actions should the CCO take in response? (Hint: There are 2 correct answers).

• Investigate why employees feel empowered to violate the rules.
• Rewrite the company’s Code of Ethics to avoid future failures.
• Publicize the name of each employee who violated the rules, along with their punishment, as part of the “Punishment / Scare Them” Theory.
• Focus on implementing compliance enforcement techniques with the OSDFA Theory in mind.

Q2. True or False: Enron’s corporate governance failures were partially due to the absence of a Code of Ethics.

• True
• False

Q3. What is one criticism of the Quid Pro Quo Theory of Compliance?

• Because compliance is an integral part of running a company, employees should not feel that they are entitled to a reward for being compliant.
• A CCO might identify the wrong employees when targeting groups in need of stricter compliance monitoring.
• Foreign offices may believe that certain policies and procedures do not apply to them.
• Employees may have already developed bad compliance habits that are difficult to break.

Q4. Volkswagen falsified diesel emissions tests while making a push to be the top car company in the world. What theory of white collar crime might have driven the company’s behavior?

• The Slippery Slope Theory
• The “Everyone is Doing it” or “Virus” Theory
• The Excessive Greed or Ambition Theory
• The Reward Me Theory

Effective Compliance Programs Week 4 Quiz Answers

Quiz 1: Incident Response

Q1. True or False: Compliance officers can handle “small” compliance incidents on their own rather than enlisting a Senior Response Team to investigate or address the problem.

• True
• False

Q2. True or False: A Senior Response Team, whose role is to guide the “on the ground” incident response team through the incident response process, is composed of an organization’s CFO, CIO, and COO.

• True
• False

Q3. True or False: Companies should avoid reporting compliance failures to the media in the absence of a legal requirement to do so.

• True
• False

Q1. For some organizations, the rise in the number of rules that must be followed coupled with the requirement to proactively monitor have resulted in: (Hint: There are 2 correct answers).

• Changes in company culture
• The Board of Directors’ increased involvement in compliance matters
• An increase in non-compliant employees being removed from the workplace
• More unintentional compliance violations

Q2. Which of the following is NOT a benefit of taking regulatory reporting seriously?

• Avoiding expensive enforcement actions in the future
• Strengthening an organization’s culture of compliance
• Shoring up senior level engagement in compliance
• Controlling the message that the public receives about a breach

Q3. Two employees unintentionally violate minor compliance rules at Company X. Though the Company’s compliance training program has been reasonably effective, the violations cause the CCO to recognize the potential for further clarity. The CCO implements new technology tools to aid with instruction. Should the two accidental violators still face consequences for breach?

• Yes. If the do’s and don’ts of a compliance program have been reasonably conveyed to employees, consequences should result even from unintentional violations.
• No. Minor compliance violations need not be addressed by HR.
• Yes. Regardless of the strength of the compliance training program, unintentional violators should receive HR consequences.
• No. The compliance program was ineffective so it would be unfair to sanction the unintentional offenders.

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