Richard Bistrong – The FCPA Blog – May 31, 2016
When prosecutors, regulators, and compliance practitioners agree on anything, I pay special attention.
Last week, Compliance Week 2016 opened with a panel of Stephen Cohen, Associate Director of the SEC Division of Enforcement and Andrew Weissmann, Chief of Fraud Section of the DOJ Criminal Division. Their topic: “Are We Defining Effectiveness Correctly?”
Cohen and Weissmann were clear about the importance of the independence of the compliance function. The issue of reporting relationships, from their perspective, wasn’t as significant as the weight of compliance being able to voice disagreement, deal with conflict, and integrating into the business.
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