Comedian Brian Regan talks about his school days and waking up on the day his science project was due. He had six months to prepare his project, but had done nothing. While other kids’ parents were bringing projects in on flatbed trucks, quick-thinking Brian put dirt in a cup and called it… “Cup of Dirt.”
Of course, the OIG can recognize a cup of dirt for what it is. In fact, it is pretty clear where they stand:
“Implementing an effective compliance program requires a substantial commitment of time, energy and resources by senior management and the governing body. Superficial programs that simply purport to comply with the elements discussed and described in this guidance or programs that are hastily constructed and implemented without appropriate ongoing monitoring will likely be ineffective and could expose the organization to greater liability than no program at all. While it may require significant additional resources or reallocation of existing resources to implement an effective compliance program, the OIG believes that the long term benefits of implementing the program outweigh the costs.” – OIG Compliance Program Guidance
What influence might a well-developed compliance program have on a potential government settlement?
In 2012, the Department of Justice (DOJ) declined to bring enforcement action against Morgan Stanley in a corruption investigation based on the strength of Morgan Stanley’s compliance program. In fact, the DOJ, in its press release, praised the Morgan Stanley compliance program. Forbes labeled the compliance officer at Morgan Stanley “The Most Marketable Compliance Officer in the World.”
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Prepare. Reinforce. Go Further.