Today is the penultimate day of my 30 days to a better compliance program podcast series. Just as compliance programs sprang up, grew and began to evolve and mature in the middle of the last decade; the sophistication of the regulators has also increased. We most clearly see this in the appointment of the Department of Justice (DOJ) Compliance Counsel, Hui Chen.
With her initial public remarks, Chen provided insight into how she would See more +
Today is the penultimate day of my 30 days to a better compliance program podcast series. Just as compliance programs sprang up, grew and began to evolve and mature in the middle of the last decade; the sophistication of the regulators has also increased. We most clearly see this in the appointment of the Department of Justice (DOJ) Compliance Counsel, Hui Chen.
With her initial public remarks, Chen provided insight into how she would consider the effectiveness of a compliance program. Her key point was companies should operationalize their compliance program by tying it to functional disciplines within your company. This means that Human Resources (HR), Payment, Audit, Vendor Management and similar corporate disciplines should be involved in the operation of your compliance program in their respective areas of influence. Then in April 2016 under the remediation prong, with the initiation of the DOJ Pilot Program around FCPA enforcement, the DOJ once again emphasized the operationalization of a company’s compliance program as a key metric in determining benefits under the program. You must actually be doing compliance going forward. See less -
