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.
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.”
There’s not much available from UK regulators on what they expect from an overarching corporate compliance program. Most guidance issued to date has focused on prescriptive compliance with specific regulations. But UK corporations can look to the U.S. Department of Justice (DOJ) for a solid program template.