An effective corporate compliance program is an essential component of internal controls for uncovering and preventing ethical lapses and criminal violations and smart companies are prudently adopting these programs. However, it is not enough to merely implement the program. It is also essential the program is properly and competently administered and maintained. This article acknowledges broadly accepted fundamentals of any corporate compliance program, explores common mistakes made during implementation and maintenance of the programs, and concludes with recommendations based upon Department of Justice and Securities and Exchange Commission guidance.

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