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How character relates to compliance

Tom Fox | January 8, 2018

Some legal commentators still believe that if you put a paper compliance program in place, employees will follow it. The problem with that legal approach is that does not account for the human condition, which unfortunately is not always pure of heart.

The Man From FCPA considered that when perusing a recent book, “The Character Gapby Christian Miller. In that book, Miller writes that people are not always morally pure, but nor are they morally corrupt; they are usually “a messy blend of good and evil.” People can behave “admirably in some situations and they turn around and behave deplorably in other situations,” he writes.

I found this insight key to a critical part of a best practice compliance program: ongoing monitoring. It is through ongoing monitoring that companies should be able to detect issues that might arise before they become full-blown...

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