Not just a compliance program, but an effective compliance program: SEC, DOJ issue strong reminders

Purpose – To alert corporations of a May 2015 speech issued by a top Department of Justice Official and a May 2015 settlement agreement between a global resources company and the Securities and Exchange Commission, both of which emphasize the importance of effective corporate compliance programs and provide guidelines and recommendations for achieving compliance programs that actually work. Design/methodology/approach – Summarizes and analyzes the May 2015 speech of Assistant Attorney General Leslie R. Caldwell at the 10th Annual Compliance Week conference in Washington DC and the May 2015 settlement between BHP Billiton and the SEC to settle Foreign Corrupt Practices Charges. Findings – The Department of Justice and the Securities and Exchange Commission continue to scrutinize not just whether corporations have compliance programs in place, but whether the compliance programs are actually effective. Originality/value – Practical guidance from experienced compliance professionals based on recent government opinions and actions concerning corporate compliance programs.