Tagged: ineffective compliance program

The Delusion of a Barebones 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...

Cleaning Up a Compliance Program Mess

Cleaning Up a Compliance Program Mess

You have just been hired as the new Chief Compliance Officer of a global company operating in over 80 countries, including numerous high-risk corruption countries. You have no staff and have been given a budget to hire 5 full-time professionals, support staff, and technology, if reasonably priced. When you look into the existing compliance program, you realize that everything is a mess. There are no...