MyComplianceOffice Blog

The French Anticorruption Agency (FAA) made an unsuccessful attempt to take its first enforcement this July as reported by a JD Supra news alert. The move followed the regulator’s three-month audit of an undisclosed company's corporate compliance program.  

Recently, we held a live webinar with special guest Susan Divers from LRN to get her take on the expanded guidance released 30 April, 2019. We thought we’d pick her brain further on this guidance and on high-performing compliance programs.

It’s a tricky thing to understand what a high-performing compliance program actually looks like. Aside from activities and checklists and even anonymous tips, a high-performing compliance program must include the human element. Do we, as a company, believe we’re always doing the right thing? Because in the end, that is what compliance is all about.

We’ve been fortunate to work with and have at MCO some of the most respected leaders in the compliance space. And from them, we’ve crafted a few best practices for high-performing compliance programs that everyone can easily put into place.

What makes a high impact compliance program? Given the state of many corporate compliance programs, it’s a question we get a lot. Here at MCO, we look at more than just the checklist of activities or the features or even the hotline to report potential violations. Fundamentally, business has shifted from simple checklists to how behavior is being impacted.

The Department of Justice (DOJ) has provided updated guidance for prosecutors evaluating corporate compliance programs’ adherence to Foreign Corrupt Practices Act (FCPA). “Okay,” you might be saying to yourself. “I know that already, the DOJ’s new guidance is very helpful.”