Building a World-Class Compliance Program: Best Practices and Strategies for Success


Praise for Building A World-Class Compliance Program

"The globalization of business and communications presents unprecedented opportunities for successful growth in many industries and for companies large and small. Conversely, the compliance challenges faced by businesses worldwide have never been more challenging. The urgency to develop a world-class compliance program has never been greater. This book is a must for all companies facing today and tomorrow's compliance challenge."
John Connors, Partner at Ignition Partners and former CFO, Microsoft Corporation

"Unbiased, well researched, comprehensive, and interesting.A great resource for compliance professionals and a great read for CEOs, management, and board members who care about doing the right thing. I have been involved with the production of over 150 compliance articles, books, magazines, and newsletters, and Martin's work is among the best I have seen."
Roy Snell, CEO, Society of Corporate Compliance and Ethics

"Martin slices through the confusion surrounding corporate compliance and offers not only useful guidelines, but a step-by-step approach to establishing an effective program. Building a World-Class Compliance Program is essential for anyone concerned with compliance and ethics within organizations."
James D. Ratley, CFE President, Association of Certified Fraud Examiners

"Martin Biegelman, with strong contributions from Daniel Biegelman, provides businesspeople with an exceptionally important book in Building a World-Class Compliance Program: Best Practices and Strategies for Success. This book clearly demonstrates how value is added to companies who get it right in this vital aspect of business. Each chapter contains concrete examples of best practices ensuring compliance, backed by solid supporting examples. Together, they interview some of the best authorities in this field, and draw from Martin's experience as a federal law enforcement agent and executive."
Edward M. Stroz, Co-president of Stroz Friedberg, LLC, and former FBI special agent

"Gone are the days when compliance programs were optional or companies could just have faith that none of their employees would go astray. Today's organizations need compliance programs and strategies in place. Martin Biegelman has written the consummate guide."
Joel Bartow, CFE, CPP, Director of Fraud Prevention and Investigations, Sitel Corporation

Martin T. Biegelman has been fighting fraud for more than thirty years in various roles in law enforcement, consulting, and the corporate sector. He is currently Director of Financial Integrity for Microsoft Corporation, where he built and leads a worldwide fraud detection, investigation, and prevention program. Biegelman is a Certified Fraud Examiner and a sought-after speaker and author on white-collar crime, corruption, fraud prevention, and compliance issues. He is the coauthor of Executive Roadmap to Fraud Prevention and Internal Control, also published by Wiley.
Foreword xi

Preface xiii

Acknowledgments xvii

About the Author xix

CHAPTER 1 Why Ethics and Compliance Will Always Matter 1

CHAPTER 2 Tone at the Top and Throughout 25

CHAPTER 3 The Growth and Evolution of Compliance 45

CHAPTER 4 Caremark and Sarbanes-Oxley: Enhancing Compliance 71

CHAPTER 5 CA's Compliance Rebirth: Don't Lie, Don't Cheat, Don't Steal 87

CHAPTER 6 The International Landscape of Compliance 107

CHAPTER 7 Compliance Programs and Anti-Money Laundering Efforts 131
By Marc B. Sherman, Laura Connor, and David Meilstrup

About the Chapter Authors 148

CHAPTER 8 Interview with an Ethics and Compliance Thought Leader 149

CHAPTER 9 Building a World-Class Compliance Program: The Seven Steps in Practice (Part I) 163

CHAPTER 10 Building a World-Class Compliance Program: The Seven Steps in Practice (Part II) 191

CHAPTER 11 Recognizing Compliance Excellence: Premier, Inc. and Winning the Baldrige Award 219

CHAPTER 12 Designing Robust Fraud Prevention Policies: The Airservices Australia Fraud Control Plan 233

CHAPTER 13 The Skunk in the Room 257

Appendix A: Summary of the 2004 Federal Sentencing Guidelines Amendments and Recommended Action Steps 269

Appendix B: Sample Compliance Program Charter 277

Appendix C: Resources for Compliance Professionals 283

Index 291