Creating an Effective Compliance Program
For many corporate counsels, "culture" and "compliance" seem to be mutually exclusive concepts.
Culture is squishy and conceptual. Compliance is definitive and measurable. Follow the seven steps in the Federal Sentencing Guidelines, and, voila, you have a compliance program. Why would corporate counsel even have to bother with the whole idea of managing their company's culture? That's an HR issue.
But the world of compliance has changed, and chief legal officers are actively learning how to manage this new reality.
Compliance programs have proliferated since the enactment of the Federal Sentencing Guidelines and the landmark 1996 Delaware Chancery Court decision In re Caremark. But the promulgation of compliance programs hasn't led to less compliance violations and ethics scandals.
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