“People are doing the best that they can from their own level of consciousness.” — Deepak Chopra
If you travel on the anti-corruption seminar circuit (which is far more enjoyable than the proverbial “rubber chicken” circuit), you will hear from some of the most accomplished compliance professionals working at Fortune 50 companies. They are proud, and should be, about the compliance programs they oversee and helped design and implement. These are the “Cadillac[s]” of compliance programs. Everyone can learn important lessons from these programs. Most of these companies have compliance programs that are well designed, operate efficiently and stand out as model programs.
But for most companies these programs do not have any relevance. Approximately 40 percent of all Fortune 500 companies do not have a specific FCPA program in place, other than general statements of compliance as part of an overall code of conduct or general legal compliance program.
Most companies are designing and implementing compliance programs based on Department of Justice guidance and with the assistance of outside professionals. As companies face these issues, here are some general tips for developing compliance programs.
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