What is Adequate? In appraising a compliance program, the DOJ and SEC consider whether a company has sufficient resources to ensure the company’s compliance program is implemented effectively. When it comes to compliance, there is no one-size-fits-all program. Adequate resources may be measured in different ways. Companies may consider a variety of factors when determining what is appropriate for their specific business needs. What follows are basic suggestions to measure adequate resources. Size. For smaller sized companies, it may be appropriate [...]

Compliance as a marketing campaign As the Department of Justice and the Securities Exchange Commission increase the number of investigations, corporations ask, “What can we do to prevent corruption?”  The solution is… Create a Culture of Compliance to positively influence your employees. International laws such as the FCPA and the UK Bribery Act require companies to establish a compliance program and demonstrate efforts to prevent corruption.  Does this mean every employee must attend a compliance course? Yes, however, it means [...]