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The concept, perception and practice of compliance has evolved steadily over the past 50 years as the public, politicians, media and common sense demanded greater transparency, integrity and ethics in business. The passage of the Foreign Corrupt Practices Act (FCPA) in 1977 is just one of the more noted milestones as compliance has matured from legal cover, necessary evil and grudgingly checked box to something studied in college curriculums and given executive attention. Thankfully, compliance wasn’t left to fester in 1977.

The subject of compliance is so current, relevant and important that the U.S Department of Justice guidelines on the topic were updated as recently as April 30th of 2019 with the following press release: “The Criminal Division announced today the release of a guidance document for white-collar prosecutors on the evaluation of corporate compliance programs. The document, entitled The Evaluation of Corporate Compliance Programs, updates a prior version issued by the Division’s Fraud Section in February 2017. It seeks to better harmonize the guidance with other Department guidance and standards while providing additional context to the multifactor analysis of a company’s compliance program.”

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