Tagged: elements of compliance program

The Delusion of a Barebones Compliance Program

Instead of wrestling over the definition of an “effective” ethics and compliance program, let’s take a step back and define what we all agree on is an “ineffective” compliance program. Unfortunately, when you work in the real world, some Chief Compliance Officers, along with senior management and the members of the board of directors are supervising and administering compliance programs that fall far short of...