Manatt Partner Provides Compliance Tips to InsideCounsel
“7 Risk and Compliance Threats Facing In-House Counsel”
July 2012 – Manatt’s Jacqueline C. Wolff, co-chair of the firm’s Corporate Investigations & White-Collar Defense Practice, provided InsideCounsel with tips on how to implement and maintain a successful corporate compliance program.
According to InsideCounsel, in-house lawyers face an unending task of identifying and addressing the risks and compliance needs of mounting regulation and enforcement activity. The seven regulation issues that are deemed to be the most pressing include: Foreign Corrupt Practices Act violations, hacker attacks, insider trading, supply chains, whistleblowers, data privacy protection and economic sanctions.
Wolff offered the publication three tips that will help in-house lawyers build a successful compliance program:
- Corporate culture matters and it will trickle down. “You hear ‘tone at the top,’ and it really does mean something,” said Wolff. “If the manager of a company gives lip service to compliance, you’re going to find a company with internal control weaknesses.”
- Audit the compliance program regularly to see if it’s working for the company. “You can have the greatest compliance program in the world in terms of procedures, policies and training, but some procedures may work well in one company and fall short in another company,” said Wolff. “The only way you’re going to find out what doesn’t work is if you’re actually testing it on a regular basis.”
- Be realistic. “It doesn’t help to have very Draconian procedures that are simply not followed by personnel. You have to have things that work,” Wolff said.