Compliance and ethics programs are how organizations get their people to follow the law. When governments want organizations acting properly, they encourage effective programs. But government can also undermine programs or take ineffective approaches. There have been unfortunate instances where governments and legal systems have undermined company programs. Some enforcers have ignored programs. Governments that see value in programs may mistakenly mandate program details. Governments evaluating programs may wrongly give credit for paper and preaching, instead of real programs. They may also fail to publish examples and discuss cases. Enforcers may lack compliance and ethics expertise. In evaluating programs enforcers may take a pass/fail approach, instead of a more nuanced approach. Sometimes the mistakes defy explanation, such as where officials have tied their own hands, or rewarded companies for delaying program implementation. Finally, for those who do assessments, they may make unnecessary mistakes.


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