All companies which come before the DOJ when an incident or investigation arises claim that they have the best compliance program that they can afford in place. However, if a company cannot demonstrate the ‘robustness’ of its program it might as well be for naught. I have written several posts on three of the most important components of a FCPA best practices compliance program; which are: documentation, documentation and documentation. I believe that it is true that the only manner in which to gage the overall effectiveness of your compliance program is through documentation. Put another way, if you don’t document it, you cannot measure it and if you cannot measure it, you cannot refine it. Nevertheless, there is one more important aspect to documentation. It is through the access of this documentation that a company put forward support that its compliance program is robust.
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