Experience Matters
Sharon J. Zealey, Founder and CEO
Sharon Zealey is the founder and CEO of NextGen Compliance LLC. Since 2015, NextGen has provided compliance consulting services that are tailored to business needs such as performing investigations and risk assessments. We also formulate policies and training based on your company's culture, risk profile, policies, and Code of Conduct.
Sharon began her career in Cincinnati, Ohio as a commercial litigator. She later served as Deputy Ohio General and Assistant U.S. Attorney. She served as the presidentially appointed U.S. Attorney for the Southern District of Ohio and an international law firm partner with Blank Rome LLP. As outside counsel for The Coca-Cola Company, she was recruited in-house to handle international arbitration and compliance. She was promoted to Chief Ethics & Compliance Officer for The Coca-Cola Company and served in that role for seven years.
Sharon brings the perspective of a regulator, litigator, and compliance chief. She founded NextGen Compliance LLC in 2015. Sharon was again recruited in-house and joined client, Carestream Dental LLC, to establish its compliance program in 2017. She served as VP of Compliance for Cox Enterprises in 2018. As Founder and CEO of NextGen Compliance LLC, Sharon uses her deep experience in corporate compliance to advising national and international retail and wholesale companies.
Risk-Based Compliance
A collection of compliance guidance published by federal regulators available from the Department of Justice, Department of Treasury, and Department of Health and Human Services (see Useful Information section below). This guidance is what government regulators expect to see as a foundation of a compliance program. We have experience designing risk-based global compliance programs that achieve business objectives and full compliance laws and regulations. Reporting to the Audit Committee on how your company fulfills these obligations is essential to your success. By providing detailed reporting on the highest risks and your plan to mitigate those risks, you will achieve the high-level oversight you need to succeed.
Compliance Resources
Below are links to governmental agencies and some non-profit and public company resources to assist you.
Evaluation of Corporate Compliance Programs (Updated June 2020):
https://www.justice.gov/criminal-fraud/page/file/937501/download
Office of Foreign Assets Control, Compliance Program Framework (May 2019):
https://www.treasury.gov/resource-center/sanctions/Documents/framework_ofac_cc.pdf
Department of Justice, Criminal Division, Guidance on Evaluating Corporate Compliance Programs, April 2019:
https://www.justice.gov/opa/pr/criminal-division-announces-publication-guidance-evaluating-corporate-compliance-programs and https://www.justice.gov/opa/press-release/file/1043236/dl
Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations, July 2019:
https://www.justice.gov/atr/page/file/1182001/download
U.S. Department of Health and Human Services, Office of Inspector General
https://oig.hhs.gov/compliance/compliance-guidance/index.asp
UK Modern Slavery Act Guidance, March 2020:
Council of Europe, Group of States Against Corruption (GRECO) 2019:
European Commission, European Anti-Fraud Office (OLAF):
https://ec.europa.eu/anti-fraud/home_en
Organization for Economic Cooperation and Development (OECD):
Laws on Anti-Corruption Worldwide, a Blog by Baker and McKenzie
https://www.globalcompliancenews.com/anti-corruption/anti-corruption-laws-around-the-world/
The Essential Guide to Internal Audit and Controls by the Audit Board
https://www.auditboard.com/blog/internal-audit-controls/
Internal Controls, an Effective Framework by COSO
https://www.coso.org/internal-control
Internal Controls and Compliance
https://podcasts.apple.com/us/podcast/internal-controls-and-compliance/id1444965149?i=1000669108170
Society of Corporate Compliance and Ethics
https://www.corporatecompliance.org/all-publications
Services
Risk Assessment
Interim or Supplemental Compliance Services
Risk Assessment
We will perform risk assessments on any aspect of your compliance program based upon the DOJ Guide for corporations. Then we recommend steps to help you create a risk-based approach to compliance. This includes a risk assessment to determine a risk matrix, your highest risks and an action plan to mitigate your key risks.
Investigations
Interim or Supplemental Compliance Services
Risk Assessment
We will work with the chief compliance officer, general counsel, or outside legal counsel to perform internal investigations. We will also formulate training and internal investigation plans based on your company's culture, risk profile, policies, and Code of Conduct.
Interim or Supplemental Compliance Services
Interim or Supplemental Compliance Services
Interim or Supplemental Compliance Services
We also provide interim services as your outsourced compliance team or supplement your existing compliance team. For companies that are just establishing a compliance program, we will perform a risk assessment, establish risk priorities, prepare compliance policies, establish third-party risk management protocols, and develop training.