In the FCPA area we all know how important it is to have effective compliance programs. The DOJ’s Criminal Division and the SEC have emphasized that these programs need to be diligent, and not mere formalities. Moreover, we know that programs count to the enforcers, so we have a reason to listen to them. The FCPA Guidance tells us this, and declinations such as Morgan Stanley demonstrate it.
Entries in US Attorney's Manual (3)
The SCCE Compliance & Ethics Institute could become the focus for an annual debate within the compliance field about the critical issues ahead. In honor of the SCCE’s 10 years of supporting compliance officers, here are my top ten suggestions for next year’s SCCE agenda: