Fcpa Compliance Report

I often write about the nuts and bolts of an effective compliance program but one of the most basic things that an effective compliance program must have is a compliance department present to ask the basic questions of compliance to and receive an answer from. I think to the DOJ and SEC this means a couple of things. First, and foremost, there must be the requisite number of resources dedicated to the compliance function. This means that a compliance department must be staffed with an appropriate number of compliance professionals to do the day-to-day basic work of compliance. Head count is always important in any corporation but there must be some minimum number of people in the compliance department to answer the phone or respond to email.  But, equally important to this resource issue is providing centralized assistance and what the FCPA Guidance says is “to provide guidance and advice on complying with a company’s ethics and compliance program”. In other words, it is up the corporation to have someone the