For the global payroll specialist, there is a significant role in the operationalization of your corporate compliance program, found in the Evaluation of Corporate Compliance Programs. It poses three questions for global payroll, which may not seem particularly new, innovative, or even something different from what global payroll currently does for an organization. The Evaluation, however, with its emphasis on the operationalization of a corporate compliance program, clearly demonstrates the role of global payroll in compliance. The Evaluation requires that global payroll not only form a part of any best practices compliance program, but when it comes to the specific subject matter expertise (SME), global payroll is on the frontlines of any attempts to prevent, detect, and then remediate FCPA compliance violations.

Yet, when the three inquiries are read together, they paint a broader picture than one of simply tasking global payroll with the responsibility to prevent fraudulent leakage of money that could be used to fund bribes. The questions around the approval/certification process should be a standard part of any global payroll system. This has the effect of operationalizing the responsibility up and down the management chain from the individual employee, up through their manager(s) and eventually to the highest level of management involved in the process. This level of operationalization is designed to not only put a set of brakes in place, but also work to put a second set of eyes on the entire payroll process.

The Justice Department has now provided its clearest statement on how it expects a company to actually do compliance going forward. Long gone are the days where the DoJ simply considered the inputs of a written program as sufficient to protect companies from FCPA violations. Yet, the mandate to operationalize a corporate compliance program drives home the concept that compliance is a business process, which should be administered by the appropriate business unit with the requisite SME. When it comes to following the money, global payroll is the most well-suited corporate discipline to provide this first level of oversight and controls.