The Justice Department continues to evolve in its consideration of what constitutes a best practices compliance program. It now considers not only the authority of the chief compliance officer to report directly to the board of directors, but also such areas as the monetary and head count resources for the compliance department and the expertise of its members as well.
What resources have been made available to your organization’s compliance function? This would include both monetary budget for operationalization but also head count resources. One might hope the days have long since passed when companies would come into the Justice Department and plead the compliance function had just $100,000; $200,000; or you name the figure in resources to be met with the prosecutor’s question, “What was your annual spend on yellow-sticky note pads?” When the inevitable response was considerably more than the entire compliance budget, the prosecutor’s response was something along the lines of “Which is more mission critical for complying with the law?”
