Experience Matters
Sharon J. Zealey, Founder and CEO
NextGen Compliance LLC founder and CEO is Sharon J. Zealey. We provide compliance consulting services that are tailored to your business such as performing investigations and risk assessments. We also formulate policies and training based upon your company's culture and Code of Conduct.
Sharon began her career in Cincinnati, Ohio as a commercial litigator. She later served as Deputy Ohio General, Assistant U.S. Attorney, 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 later recruited in house. For seven years she served as Chief Ethics & Compliance Officer for The Coca-Cola Company. She 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 and likewise served as VP Compliance for Cox Enterprises in 2018. Sharon has deep experience across several industries in every area of compliance.
Risk-Based Compliance
There is 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 with law 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 that you need to succeed.
We provide compliance consulting services that are tailored to your business. We 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.
Useful Information
Compliance Officers should keep important information on their desktops.
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:
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):
https://www.oecd.org/coronavirus/en/
This guidance is important because it promotes a risk-based approach to the design and implementation of your corporate compliance program. Upon request, we'll be happy to send you the NextGen Compliance Risk Scorecard as a framework for a self-directed risk assessment. It's based upon the DOJ guidance and can be used for any size business in any industry.
Governmental Enforcement Actions
Apple
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20191125.aspx
MID SHIP
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20190502.aspx
Touchstone Medical Imaging
Southwest Securities
https://www.sfc.hk/edistributionWeb/gateway/EN/news-and-announcements/news/doc?refNo=20PR45
Amazon
https://www.treasury.gov/resource-center/sanctions/CivPen/Documents/20200708_amazon.pdf
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 chief compliance officers or general counsel to perform internal investigations. We will also formulate training and internal investigation plans based upon your company's culture, 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, evaluate compliance vendors, prepare compliance policies, establish third-party risk management protocols, and develop training.