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Articles

Three simple questions to an effective compliance program

December 23, 2013

Articles

Three simple questions to an effective compliance program

December 23, 2013

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In the modern age of global anti-corruption enforcement, an effective compliance program is no longer a luxury, it is a necessity.  Unfortunately, there is no magic formula that a company can follow in setting up or improving a compliance program.  This does not mean that a company must proceed blindly, however.  Past enforcement actions and declinations, as well as government publications such as the FCPA Resource Guide, offer insight into the basic structures that lead to effective compliance.  Drawing on these sources, there are three questions every company should ask in analyzing its compliance program.

First, is the compliance program well designed?

A well-design program is one with oversight, autonomy, and adequate resources. Read more…

Second, is the compliance program being applied in good faith?

It is absolutely essential that those in charge of the compliance program have the wherewithal to challenge unacceptable practices, particularly since the business side may try to justify the practice as “business as usual” or something that has “always been done.” Read more…

Third, is the compliance program working?

Don’t test the laws of entropy. Even the best system can fail and will eventually falter without some tweaking. Read more…

This blog post first appeared on Fish’s Litigation Blog and can be read in full here.

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