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Continuous monitoring to continuous improvement

Tom Fox | February 11, 2018

Under Hallmark Nine of Ten Hallmarks of an Effective Compliance Program as articulated in the 2012 FCPA Guidance, it stated, “Finally, 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, the DoJ and SEC evaluate whether companies regularly review and improve their compliance programs and not allow them to become stale.”

Continuous improvement requires that you not only audit but also monitor whether employees are staying with the compliance program. In addition to the language set out in the 2012 FCPA Guidance, two of the seven compliance elements in the U.S. Sentencing Guidelines call for companies to monitor, audit,...

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