“In recent days the Department of Justice and the Securities and Exchange Commission have issued strong messages reemphasizing the importance of effective corporate compliance programs.
Assistant Attorney General Leslie R. Caldwell, speaking at the 10th Annual Compliance week conference in Washington, DC last week, stressed the necessity for companies to design compliance programs “that don’t just look good on paper, but actually work.”
Caldwell warned that although a risk-based approach to compliance may be appropriate, companies “often misdirect their focus to the wrong type of risk,” resulting in reactive, rather than proactive, compliance programs. An effective compliance program, Caldwell says, is “tailored to the unique needs, risk and structure” of the company and focuses on the company as a whole, rather than just those lines of business subject to regulation.”
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