2 Corporate Compliance Program: What and Why 2 Corporate Compliance Program: What and Why

2.1 Objectives and Discussion Questions 2.1 Objectives and Discussion Questions

This chapter examines the evolution of the compliance profession and the genesis of the "seven elements of an effective compliance program" rubric. This seven element structure is the blueprint that a compliance professional uses to build and manage a corporate compliance program. It is the evidence that a regulator or prosecutor looks for in exercising enforcement discretion.

1. What would be the best reasons for a corporation to NOT have a compliance program?

2. If you were a CEO, would you want separate compliance, ethics, and risk functions? Why or why not?

3. What is your 150 word definition for a "compliance program"?

2.5 Sample Corporate Integrity Agreement (CIA) 2.5 Sample Corporate Integrity Agreement (CIA)