Building a World-Class Compliance Program

Written by a long-standing practitioner in the field, this timely and critical work is your best source for understanding all the complex issues and requirements associated with corporate compliance. It provides clear guidance for those charged with protecting their companies from financial and reputational risk, litigation, and government intervention, who want a robust guide to establish an effective compliance program.

Foreword xi Preface xiii Acknowledgments xvii About the Author xix CHAPTER 1 Why Ethics and Compliance Will Always Matter 1 CHAPTER 2 Tone at the Top and Throughout 25 CHAPTER 3 The Growth and Evolution of Compliance 45 CHAPTER 4 Caremark and Sarbanes-Oxley: Enhancing Compliance 71 CHAPTER 5 CA's Compliance Rebirth: Don't Lie, Don't Cheat, Don't Steal 87 CHAPTER 6 The International Landscape of Compliance 107 CHAPTER 7 Compliance Programs and Anti-Money Laundering Efforts 131 By Marc B. Sherman, Laura Connor, and David Meilstrup About the Chapter Authors 148 CHAPTER 8 Interview with an Ethics and Compliance Thought Leader 149 CHAPTER 9 Building a World-Class Compliance Program: The Seven Steps in Practice (Part I) 163 CHAPTER 10 Building a World-Class Compliance Program: The Seven Steps in Practice (Part II) 191 CHAPTER 11 Recognizing Compliance Excellence: Premier, Inc. and Winning the Baldrige Award 219 CHAPTER 12 Designing Robust Fraud Prevention Policies: The Airservices Australia Fraud Control Plan 233 CHAPTER 13 The Skunk in the Room 257 Appendix A: Summary of the 2004 Federal Sentencing Guidelines Amendments and Recommended Action Steps 269 Appendix B: Sample Compliance Program Charter 277 Appendix C: Resources for Compliance Professionals 283 Index 291