There's no one-size-fits-all compliance program. Depending on a variety of factors such as size, type of business, industry and risk profile, an organization should determine what is appropriate for its own needs regarding a FCPA compliance program. The following are 10 tips meant to provide insight into what the SEC looks for in a compliance program. Have a read through these and use them to assess your own compliance regime.
The SEC whistleblower who first received an award payout under the Dodd-Frank program more than two years ago, will collect an additional $150,000 thanks to more funds recovered in the case. This whistleblower, not yet identified in order to protect confidentiality, has now been paid about $200,000. The first Dodd-Frank award was announced in August 2012. This whistleblower helped the SEC stop a multi-million dollar fraud. He/she provided documents and other information that allowed the agency's investigation to move quickly and prevent more victims from being harmed.
Businesses can often feel they are relatively safe and protected from fraud, especially when they are smaller businesses. In fact, studies have shown smaller businesses are more vulnerable because they don't have the resources to put the proper safeguards in place and ensure internal controls are working.
We do not live in a culture of silence anymore. Much effort has been spent by many organizations to create a culture of integrity and transparency where workers feel safe to come forward and speak when they have concerns about wrongdoing.