One of the three generally sourced cited as a benchmark of the elements of an effective compliance program is the Organization for Economic Co-operation and Development (OECD) Good Practice Guidance on Internal Controls, Ethics, and Compliance. In the June issue of the Society of Corporate Compliance and Ethics Magazine (SCCE) (Vol. 7 / No. 3) was found an article by our colleague Russ Berland on these elements. Given the recently released Bribery Act Guidance referenced this document, we believed a review of these elements was appropriate.