Fcpa Compliance Report

In metrics laid out by former Assistant Attorney General Leslie R. Caldwell, she spoke about the need for compliance program incentives.  She posed it with the following question, “Are there mechanisms to enforce compliance policies? Those include both incentivizing good compliance and disciplining violations.”  I think most compliance professionals understand the need to discipline employees who may have violated the Foreign Corrupt Practices Act (FCPA) or otherwise engaged in bribery and corruption. However, many CCOs and compliance practitioners do not focus as much attention to compliance incentives. I have developed six core principles for incentives, adapted from an article in the Spring 2014 issue of the MIT Sloan Management Review entitled “Combining Purpose with Profits” and reformulated them for the compliance function in an anti-corruption compliance program.  Compliance incentives don’t have to be elaborate or novel. The first point is that there are only a limited number of compliance incentives