Leslie Caldwell, chief of the DOJ’s criminal division, spoke at the Compliance Week Conference in Washington, D.C. Tuesday. After talking about some defenses that don’t work, she described the ten hallmarks of an effective compliance program, and she warned companies to obey all the laws they’re subject to.
Here’s part of what she said:
Too often we have heard companies say that a particular course of criminal conduct took them by surprise, when a hard look at the business practices would have identified the risk. And, far too often, we have heard companies exclaim in defense that everyone else is doing it — that others in the industry are engaged in the same misconduct.
But as you all know, an industry-wide compliance failure is not a defense to knowing and willful criminal activity.
The original article can be found at www.fcpablog.com