Compliance is front and center in most large companies, but many treasury teams are too lean to implement critical controls.
By Treasury & Risk Staff |
Updated on June 25, 2013
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Robert Biskup: The past 15 years have been a very dynamic period of development in corporate compliance programs. In the pre-SOX [Sarbanes-Oxley] era, companies that weren’t in highly regulated industries, such as defense or financial services, commonly had compliance programs that consisted of a vision statement and little else. I think of that as the first generation of corporate compliance programs. Then, post-SOX, a lot of corporations started doing a good job of enhancing their vision statements; publishing robust codes of conduct; expanding their policies and procedures; and enacting everything that SOX specifically called for, including whistle-blower and incident-management programs. But despite these proactive aspects of compliance, some of the back-end aspects—around assurance, auditing, monitoring, things of that nature—were lagging. I think what we are seeing now is the unfolding of the third generation of corporate compliance programs. Companies have spent 15 years in an incubation period, filled with trial and error and experimentation. Now they have a better understanding of what the effective elements of a compliance program ought to look like.
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