Compliance Programs: Step-by-Step Guide to Building and Scaling Effective Programs from Start-Ups to Large Enterprises

Abstract

Business operates in a world of risks including geopolitical, regulatory, environmental, and macroeconomic. Many of these risks cannot be controlled. On the other hand, “conduct based risk”, or risks stemming from the actions of employees and agents of a Company can be mitigated through an effective compliance program. Building a program capable of effectively addressing these risks can be daunting, especially for companies that do not have an existing compliance program serving as a foundation. This paper sets forth the steps needed for any size company to design, build, and maintain a program that will meet or exceed the standards of enforcement agencies and protect the Company from fines, sanctions, and reputational harm.