No area has become more challenging in compliance than continuous improvement. The 2012 FCPA Guidance specified that “a good compliance program should constantly evolve. A company’s business changes over time, as do the environments in which it operates, the nature of its customers, the laws that govern its actions, and the standards of its industry. In addition, compliance programs that do not just exist on paper but are followed in practice will inevitably uncover compliance weaknesses and require enhancements. Consequently, DoJ and SEC evaluate whether companies regularly review and improve their compliance programs and not allow them to become stale.”
