31 Days to a More Effective Compliance Program -Taming Complexity in Compliance

Thomas Fox
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One of the lessons we have learned from various FCPA enforcement actions over the years is how complexity in business organizations can work to defeat compliance programs. Whether a corrupt employee is working to actively hide a pot of money, which can or will be used to pay a bribe, or an improper payment slips through the cracks; complexity can work to defeat a best practices compliance program. If a compliance function does not have visibility into a business unit, how it does business and where its payments are going; it may be See more +
One of the lessons we have learned from various FCPA enforcement actions over the years is how complexity in business organizations can work to defeat compliance programs. Whether a corrupt employee is working to actively hide a pot of money, which can or will be used to pay a bribe, or an improper payment slips through the cracks; complexity can work to defeat a best practices compliance program. If a compliance function does not have visibility into a business unit, how it does business and where its payments are going; it may be due to design defect or inadvertent complexity.

Three key takeaways:

1. Not all complexity is bad.

2. If you cannot figure out how a foreign does business you have a problem.

3. Compliance is now properly seen as a business process. 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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