31 Days to a More Effective Compliance Program - Revising your policies and procedures

Thomas Fox
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Simply having a Code of Conduct, together with compliance policies and procedures is not enough. As articulated by former Assistant Attorney General Lanny Breuer, “Your compliance program is a living entity; it should be constantly evolving.” The 2012 FCPA Guidance stated, “When assessing a compliance program, DOJ and SEC will review whether the company Guiding Principles of Enforcement has taken steps to make certain that the Code of Conduct remains current and effective and whether a company has periodically reviewed and updated See more +
Simply having a Code of Conduct, together with compliance policies and procedures is not enough. As articulated by former Assistant Attorney General Lanny Breuer, “Your compliance program is a living entity; it should be constantly evolving.” The 2012 FCPA Guidance stated, “When assessing a compliance program, DOJ and SEC will review whether the company Guiding Principles of Enforcement has taken steps to make certain that the Code of Conduct remains current and effective and whether a company has periodically reviewed and updated its code.”

Three key takeaways:

1. If you have not revised your compliance policies and procedures in the past five years, you should do so now.

2. Set a timeline and budget and stick to it in the compliance policy and procedure revision process.

3. Document your process of revision to demonstrate more complete operationalization of your compliance program. See less -

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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