8. Minimizing Vulnerabilities to Government Investigations
The Department of Justice provides business leaders with a roadmap for best-in-class compliance programs. Companies may remain “willfully blind” of what prosecutors expect to see in compliance programs. Yet blindness will not protect them.
Prosecutors want companies to show a good-faith effort to operate in compliance with laws and regulations. They should review the programs regularly and offer new material regularly. Failing to update compliance programs may result in a company being more vulnerable or make the company less likely for leniency.
Compliance requires constant updating and universal enforcement on a regular basis. Prosecutors want to see compliance as an inherent part of a company’s corporate culture, inducing employees to act appropriately at all times. Good compliance programs should promote transparency and efficiency.
Big government leads to greater supervision and enforcement. Companies can no longer rely on luck or chance as a corporate compliance strategy. The Department of Justice has clearly designated corporate fraud as a hot button topic, but also provided guidance on how to best avoid being the subject of an investigation or prosecution.
For reasons expressed throughout these modules, every business leader should consider possible steps to lessen potential exposure to a government investigation. Three suggestions follow:
- Show a commitment “to doing good” in all communications.
- Document processes that show a commitment to operating the business with principled, transparent policies that are easily defensible.
- Train all team members to understand the corporate culture, and also the reasons behind every policy in place.
Incorporating these three components would go a long way toward protecting businesses and individuals.
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