An effective corporate compliance program must be built on a foundation of ethics and integrity that is practiced by senior management. Nonetheless, robust compliance managment requires more than just support from the top. Organizations must have compliance officers in positions that allow them direct and unfettered access to the board and the authority and resources to ensure the compliance program is effective on a day-to-day basis.

Personnel structures should include full-time compliance staff and a meaningful compliance presence in the organization’s subsidiaries, business units and foreign operations. Regulatory authorities now assess compliance expertise within the board’s membership and whether the board holds executive sessions with the compliance team. Another sign of effective compliance is meaningful collaboration between the senior leadership and other company stakeholders, including business and operational managers, human resources, procurement and accounting. Effective compliance requires buy-in from all levels of the organization’s hierarchy.