One of the things that any compliance program should have baked into it is independent oversight. Indeed there should be multiple levels of oversight. This requirement for oversight did not arise from the world of anti-corruption compliance but from process engineering, which mandates that for any process to be valid there should be independent oversight, or as my wife would say “a second set of eyes.” The Man From FCPA considered this requirement for additional eyes after seeing that the mobile phone manufacturer Samsung self-tested its Note 7 batteries.
