The Three Keys to Compliance Programs: Structure, Processes and Results

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2 Responses

  1. Michael,

    Could not agree more. Keep it simple and measure by results. This means of course knowing what results you are measuring against and therefore being willing to compare yourself to those outside your organization who – just possibly – do it better. This is no place for egos.


  2. Monitoring the results as recommended in the new DOJ guidance can be a powerful concept.

    It all comes back to the management maxim of “you get what you measure”. Take the Hawthrone Effect – a form of reactivity where subjects improve or modify an aspect of their behavior being experimentally measured simply in response to the fact that they know they are being studied, not in response to any particular experimental manipulation.

    Obviously identifying the material “stop everything we’ve got a problem” type transaction drives value but those finds are hopefully few and far between. Where we’ve seen this be particularly powerful is by using the monitoring to generate “compliance reminders” that point out how a specific T&E expense could be questionable from an FCPA standpoint. To do this your monitoring efforts need to be integrated with the other elements of the FCPA program – such as training, policy and communications, among other factors.

    – Patrick Taylor, CEO,