A blog post on the FCPA Blog on 22nd February provided 6 common pitfalls and blind spots related to building and maintaining a compliant organisation –
- Failing to look at the external operating environment in your compliance risk assessment;
- Considering impact only in terms of compliance enforcement;
- Over-focus on list-based, reactive sanctions management;
- Failing to achieve a sustainable use of resources;
- Not testing, monitoring or doing on-the-ground checks; and
- Generic training.