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To operationalize compliance, pick up the phone

Tom Fox | December 5, 2017

One of the most basic things that an effective compliance program must have is a compliance department that can answer all your questions. There must be the requisite number of resources dedicated to the compliance function, which means that a compliance department must be staffed with an appropriate number of compliance professionals to do the day-to-day basic work of compliance. Head count is always important in any corporation but there must be some minimum number of people in the compliance department to answer the phone or respond to e-mail.

But equally important to this resource issue is providing centralized assistance and what the 2012 FCPA Guidance says is “to provide guidance and advice on complying with a company’s ethics and compliance program.” It is up to the corporation to have someone present to answer the phone, but once they put someone in that compliance department seat, that person has to actually pick up the phone and respond. It is the responsibility of...

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