Implementation Challenges and Value of Systemic Root Cause Analysis within Fraud Cybersecurity and Financial Crime Management

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Research Paper ABSTRACT Since the 1990s the United States Department of Justice has evaluated adequacy of compliance programs when deciding to prosecute corporations. Beginning in April of 2019 corporations are expected to undertake adequate and honest root cause analysis of their wrongdoing and failures of compliance systems.
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  • Implementation Challenges and Value of Systemic Root Cause Analysis within Fraud Cybersecurity and Financial Crime Management

    Research Paper ABSTRACT Since the 1990s the United States Department of Justice has evaluated adequacy of compliance programs when deciding to prosecute corporations. Beginning in April of 2019 corporations are expected to undertake adequate and honest root cause analysis of their wrongdoing and failures of compliance systems. Failures to remediate issues through this new approach increase their likelihood of prosecution. Architects of the guidance point to the value of systems thinking and successes of root cause analysis in aviation for corporations to emulate. A decade after regulators identified use of this problem-solving intervention for fraud, cybersecurity and financial crime management, there still exists no detailed guidance for its implementation. There is also a fundamental lack of existing empirical literature on the topic. It was established that healthcare’s adoption of root cause analysis from aviation was largely ineffective. Lack of practitioner time, resources, and expertise were identified as causes. Policymakers failed to adapt the approach from aviation by not addressing blame or the impacts of power. Experiences from healthcare identify serious challenges for the use of this tool against corporate crimes. Recommendations and future research considerations were provided regarding increased empirical understanding, regulatory guidance, integration with corporate investigations, enhanced education, and cybersecurity workforce training. Root cause analysis is a valuable intervention for learning in complex sociotechnical systems. Where acted upon, these recommendations will help corporations implement it effectively to increase learning and create systemic changes that prevent unnecessary fraud and cybersecurity issues. Keywords: Cyber Policy and Risk Analysis, Dr. Kyung-Seok Choo, root cause analysis, human factors, compliance. REFERENCE: Dunlop, P. (2019, August). Implementation Challenges and Value of Systemic Root Cause Analysis within Fraud C

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