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. 

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Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in...