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A RISK-BASED FRAMEWORK FOR ASSESSING A …

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. Organizational Dynamics that Shape a compliance culture 8 E. ASSESSING a compliance culture , is it important? 9 IV. THE RISK-BASED ASSESSMENT FRAMEWORK 9 A. Overview of the Assessment FRAMEWORK 9 B. Low Risk: an Engaged culture 11 C. Medium Risk: a Disconnected culture 11 D. Medium Risk: a Disoriented culture 12 E.

A Risk-Based Framework for Assessing a Compliance Culture P a g e 4 | 36 Under the integration perspective, a “culture sees consensus.”10 For example, in institutions where abiding by the law is highly valued, strict compliance would be a

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