One of the areas articulated in the 2019 Guidance was around payments and payroll. For both the compliance professional and the corporate payroll function, there is a significant role to play in the operationalization of a corporate compliance program. The Evaluation of Corporate Compliance Programs - Guidance Document (2019 Guidance) was replete with references to payment and its critical nature to any best practices compliance program. This includes references to payments to foreign officials, payments to third parties and hiding See more +

One of the areas articulated in the 2019 Guidance was around payments and payroll. For both the compliance professional and the corporate payroll function, there is a significant role to play in the operationalization of a corporate compliance program. The Evaluation of Corporate Compliance Programs - Guidance Document (2019 Guidance) was replete with references to payment and its critical nature to any best practices compliance program. This includes references to payments to foreign officials, payments to third parties and hiding bribes in payments to distributors.

The 2019 Guidance begins with an admonition to stop wasting time on low hanging fruit when there are much higher risks in your business operations. Taken together, these questions may not seem particularly new, innovative, or even something different from what payroll currently does for an organization. However, the 2019 Guidance , clearly demonstrates the role of payroll in compliance. The 2019 Guidance requires that payroll not only form a part of any best practices compliance program, but when it comes to the specific subject matter expertise, payroll is on the front lines of any attempts to prevent, detect, and then remediate anti-corruption compliance violations.

Three key takeaways:

1. Payroll can be a key prevent and detect control.

2. The 2019 Guidance specified the tying of the corporate compliance function to the corporate payroll function.

3. Offshore payments remain a key indicator for a red flag.

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