Building a World-Class Compliance Program: Best Practices and Strategies for Success

Preface

When I wrote my first book, Executive Roadmap to Fraud Prevention and Internal Control: Creating a Culture of Compliance, co-authored with Joel Bartow, there was a common theme running throughout the work. It was that fraud, abuse, and non-compliance with policies and laws would always be concerns for all organizations, large or small, public or private, foreign or domestic. Yet, much could be done in the way of program development, robust fraud prevention, compliance oversight, and executive leadership to dramatically lessen compliance failures. In many ways, this book is a companion to that book in that it continues and expands on many of these themes.

Although the corporate scandals of Enron, WorldCom, Tyco, Adelphia, and others are mostly history now, we said that other frauds and compliance issues would continue to rear their ugly heads. it didn't take long for our prophecy to come true. Backdating of stock options, bribery and corruption, insider trading, corporate spying, and pretexting scandals have all made global headlines over the last few years. As of the writing of this book, more than 140 corporations are under investigation by the Securities and Exchange Commission and Department of Justice in the United States, as well as subject to internal probes for backdating stock options. Corporate executives have been removed and some have been prosecuted and convicted. As New York Yankee great Yogi Berra has said, "It seems like déjà vu all over again."

Early in my ...