In the frenzy of upsizing, downsizing and rightsizing compliance programs after downturns in the market or in the midst or aftermath of a major investigation, it’s important to keep in mind that experienced lawyers and compliance professionals bring significant value to a company.
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With every enforcement action comes lessons and warning tales for other companies and compliance officers. Last week Qualcomm paid $7.5 million to settle SEC charges that it violated the Foreign Corrupt Practices Act by hiring relatives of Chinese officials responsible for deciding whether to select the company’s mobile technology products.
I'm often asked for my thoughts about the future of compliance. What people really want to know is, what's the next level of compliance? How do we improve? For me, the answer is corporate consciousness.
Corporate compliance programs are no longer classified as “nice to have,” nor are they mere responses to allegations of wrongdoing. Some companies are going beyond mentioning how they have cleared their names with regulators after an investigation; they're actively promoting the components of an effective strategy.