The operationalization of your compliance programs means how deeply compliance is integrated into the function of your company. One of the ways to do so is through a compliance oversight committee.
The compliance oversight committee sits between the chief compliance oficer and the board’s compliance committee. The role of the compliance oversight committee is to review high-risk issues, such as third-party approvals and renewals, requests for payments from third parties and significant gift, travel and entertainment requests from employees. This committee’s oversight demonstrates not only a shared committee to compliance as required under the Justice Department’s Evaluation of Corporate Compliance Programs, but also fulfills the requirement for engaged senior management oversight as a part of a company’s management of risk.
The role of the compliance oversight committee is not to substitute its judgment for that of the CCO, but rather to provide another level of review to make sure nothing slips through the cracks that might expose the company to unwanted risk. This can begin with a clear, written charter that sets out the functionality, goals, and parameters of the group. Moreover, the compliance oversight committee should be reviewed on a periodic basis to determine usefulness and effectiveness.
The oversight of foreign business partners is one of the key mechanisms that a company can use to prevent and detect any violation of its own code of ethics and compliance and the FCPA. The proper structure of the compliance oversight committee and its full engagement with all aspects of a company’s relationship with a foreign business partner is one of the areas that the Department of Justice will look for in a successful FCPA compliance program.
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