The more one thinks about anti-corruption compliance the more it is clear how each part of a corporation has role in such compliance. This is because, unlike the legal function, which will almost always stand separate and apart from other corporate disciplines, the role of compliance should be more integrated into an organization.
A board of directors must set the appropriate tone at the top for any organization. Yet it must do more than simply set the tone, sit back and do nothing. A board needs to take a hard look at the information it is being presented and tell management to stop if the executives are walking up to a line over which they could cross into illegal conduct. Enron is but one notorious example, where the CFO presented off the books information to the board. Apparently no one on the board thought to say stop or even wait a minute.
