Compliance breaches are costly, time consuming, a
distraction and embarrassing. In many cases, it can result in
the implosion of the company itself. Witness the Enron scandal,
and more recently, the case of Satyam. Both were companies
ironically hailed for their compliance programmemes and
infrastructure but had ethical issues at their core.
As a result, companies are seeking quick solutions by
implementing compliance programmes. Much has been written about
what constitutes an effective compliance programme. Many of
these naturally hinge on what your respective regulators
consider to be necessary elements of a compliance programme
(see for example the Bureau of Industry and Security's
Principles of Effective Compliance Programmes and the
Australian Competition and Consumer Commission's thoughts): a
documented risk analysis, a compliance manual or code of
conduct, the existence of a structured compliance organisation
and so forth.
Another popular source of guidance comes from Chapter 8 of
the US Sentencing...