This client had historically operated with a highly decentralized compliance environment where numerous people and functions had compliance responsibility, which was considered a major factor in leading this company into very significant financial and regulatory trouble. Our professionals were engaged to design a new, enterprise-wide compliance program and create a new, centralized compliance function.
- Created a compliance framework that was adopted by the board.
- Designed a new compliance function and job description and assisted with staffing and candidate search and evaluation.
- Developed the core procedures for the compliance function, including risk assessment and evaluation, policy development, communication, monitoring and reporting procedures.
- Planned a variety of risk-based initiatives, including FCPA, international obligation and appropriate business communication initiatives.
- Designed and implemented compliance system tools, including compliance risk management, consent decree management and an international obligations system.
The company then had a virtual Compliance Education Center that integrated online compliance training, compliance policies and guidelines, compliance tools and resources and critical compliance messaging.