Root Cause Analysis: Does ‘5 Whys’ work for compliance?
Richard L. Cassin
April 6, 2023
Corporate FCPA defendants hoping for declinations must demonstrate that they’ve performed a root cause analysis and remediated the underlying conduct. The DOJ doesn’t tell companies how to do the root cause analysis, and there are many methods to pick from — Scatter Plot Diagram, Fishbone Diagram, Failure Mode and Effects Analysis (FMEA), and Pareto Chart, among others.… Continue Reading