Continuous Compliance to Solve the Problem

On this day, 53 years ago the CBS television network premiered one of my favorite TV shows of all time – Route 66. The program had a simple premise, it followed two young men, Buz Murdock and Tod Stiles, as they drove across the country in an inherited Corvette (Chevrolet was one of the show’s sponsors), doing odd jobs and looking for adventure. According to the show’s creator and writer, Stirling Silliphant, Buz and Tod were really on a journey in search of themselves. “Call “Route 66” “Pilgrim’s Progress”” once Silliphant told a reporter. “The motive power driving our two characters is not a Corvette: it is the desire for knowledge–and for sentience; it is a quest through the perennially fascinating cosmos of personal identity.”

I thought about the message of Route 66 as a continuous quest, when I wrote about the use of financial controls as a key part of your anti-corruption program under such laws that the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act. In listening to the talk by Stephen Arbogast, Executive Professor at the University of Houston, Bauer College of Business, Department of Finance, I saw, once again, that compliance is more than a set of steps but is truly a continuous process that, once implemented, takes each step in the process and builds upon another until it becomes an ongoing practice.

I have read that former Department of Justice (DOJ) official Lanny Breuer said that a FCPA compliance program should be a continuous process; further that your compliance regime should be a living, breathing practice going forward. By doing so, your business will be able to adapt to meet changing markets, circumstances and outside forces so that you can do business not only in compliance with the FCPA but also in a smarter, better and more efficient manner ...

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