An effective compliance program
not only promotes quality care, but also may prevent enforcement issues based on alleged survey deficiencies and allegations of fraud, which can result in multi-million-dollar jury verdicts and settlements.
Despite an increasingly clear understanding, among regulators and practitioners alike, of what makes an effective compliance program
, corporate slipups and scandals continue to occur regularly.
Additionally, as the DOJ has outlined in written guidance, the DOJ and SEC will punish a company more harshly for a poor compliance program
irrespective of whether it self-reports and cooperates.
This guidance specifically notes that the adequacy of a company's compliance program
is a factor that will be considered in deciding what, if any, action to take against a company for Foreign Corrupt Practices Act (FCPA) violations.
Deluxe Corporation (NYSE:DLX) announced on Monday the Deluxe Regulatory Compliance Program
, a web portal and set of services that provides regulatory information, compliance management tools and online training for community banks and credit unions across the USA.
reviewing their organization's compliance program
policies and employee handbooks to ensure that these materials meet the new standards,
Create a written compliance program
and have it approved by senior management.
A key element of any compliance program
is the ability to prove adherence to internal policies, practices, and standard operating procedures.
Every MSB is required to develop and implement an anti-money laundering compliance program
designed to ensure that the business meets the Bank Secrecy Act guidelines for documentation, reporting of certain transactions, and policies and procedures to prevent use of the business to launder money.
The Illinois legislation establishes a tax shelter voluntary compliance program
from October 15, 2004, to January 31, 2005.