The headlines in 2014 focused on some pretty big compliance failures. In December alone we saw the Alstom SA Foreign Corrupt Practices Act case with its $772,290,000 enforcement action—the second-largest U.S. FCPA penalty. And far more interesting was the Sony Pictures Entertainment Inc. cybersecurity attack delaying the opening of the latest Seth Rogan and James Franco movie and exposing sensitive Hollywood gossip. Compliance programs, however, cannot focus solely on chasing headlines. Program enhancements have to look forward. Instead of making empty promises to hit the gym or swearing off lunchtime martinis, make a New Year’s resolution to focus on your company and make some forward-looking compliance improvements to your program:
1. Develop a Risk-Based Compliance Program
Sometimes we use the phrase “risk-based program” gratuitously, like “world’s best hamburger,” without much thought given to its meaning. A risk-based program is one that uses the results of an effective risk assessment process to allocate resources to the highest risk.
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