Agency Assessments of Compliance Programs

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Joseph Murphy, Jun 30, 2015

Compliance and ethics programs are the way organizations take management steps to prevent and detect illegal and unethical conduct. They can be more or less rigorous and effective, depending on the level of commitment. Historically it has been government that drives organizations to adopt such programs, and especially to move them beyond mere paper and preaching into meaningful steps.

Enforcement authorities have recognized that their role is not simply to collect fines and obtain convictions, but to prevent violations before the harm is done. They recognize that company compliance and ethics programs are essential tools in this mission. When government takes compliance and ethics programs into account and uses them as a means to transform industry conduct, there is enormous leverage to get companies to upgrade those programs. For government to be effective in this, however, it must be credible in its assessment and imposition of programs.