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A RISK-BASED FRAMEWORK FOR ASSESSING A COMPLIANCE CULTURE By: Francisco Daniel Zepeda L zarus, PhD, MBA, CAMS, CFE, AML-CA CAMS-AUDIT Advanced Certification White Paper August, 2015 A RISK-BASED FRAMEWORK for ASSESSING a Compliance Culture TABLE OF CONTENTS I. EXECUTIVE SUMMARY 1 II. INTRODUCTION 1 III. UNDERSTANDING A COMPLIANCE CULTURE 2 A. Defining a Compliance Culture 2 B. Promoting a Compliance Culture 5 C. Similarities with Risk Culture 6 D.
based framework for assessing it, and c) determine levels of risk for assumptions of organizational dynamics. In addition, a strategy is presented on how a combination of
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