Joseph Murphy, Mar 29, 2012
The DG Comp posting speaks about ignorance not being a defense. But ignorance is not and never was the issue. It is the reality that organizations are not individuals, and that there is no means known to humans to control the conduct of every individual, every day, in any large organization. So society wisely elects to encourage organizations to make the most diligent efforts to prevent misconduct through compliance programs with the knowledge that such efforts will not and cannot be perfect. Government then distinguishes those companies that try from those that do not. DG Comp’s refusal to do so is the issue.