The role of payroll in compliance is not often considered in operationalizing your compliance program, yet the monies to fund bribes must come from somewhere. Unfortunately, one of those places is out of payroll. All CCOs need to sit down with their head of payroll, have them explain the role of payroll, and then review the internal controls to see how they facilitate compliance goals. From that review, you can then determine how to use payroll to help to operationalize your compliance See more +

The role of payroll in compliance is not often considered in operationalizing your compliance program, yet the monies to fund bribes must come from somewhere. Unfortunately, one of those places is out of payroll. All CCOs need to sit down with their head of payroll, have them explain the role of payroll, and then review the internal controls to see how they facilitate compliance goals. From that review, you can then determine how to use payroll to help to operationalize your compliance program.

Three key takeaways:

1. Payroll can be a key prevent and detecting control.

2. The 2020 Update specified the tying of the corporate compliance function to the corporate payroll function.

3. Offshore payments remain a key indicator for a red flag. See less -