The Parallels and Distinctions Between Investigations and Culture Reviews

For years, fund managers have been hearing about the importance of setting the proper tone at the top and ensuring that there is a strong culture of compliance at their firms. One way to ensure tone and culture are properly established in various risk areas is by conducting a culture review. Culture reviews require a careful combination of art and science, as well as thoughtful planning, a commitment from leadership and the establishment of a strong rapport with employees, according to a panel at the ABA’s 37th National Institute on White Collar Crime in San Francisco. This article explains the differences between cultural reviews and investigations, and it distills the insights on how to frame, define, plan and execute culture reviews. See “Leveraging Policies and Culture: A Recipe for Success” (May 31, 2022).

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