Companies conducting high-risk business, especially in corruption-prone jurisdictions, should reevaluate how compliance, legal and internal audit personnel interact with senior management and how the company budgets for these functions, a top Department of Justice official said Tuesday. High-risk areas include finance, health-related and extractive industries, and government and military contracting, as well as acquisitions and joint ventures, Marshall L. Miller, Principal Deputy Assistant Attorney General for the Criminal Division, said at a compliance and ethics event in New York. The cost of developing compliance programs tailored to a company's businesses and training programs that are appropriate for everyone from the back office to customer-facing positions to senior managers; deploying the programs; monitoring and testing their effectiveness; and improving them as needed, can be daunting, Miller said. Then add the cost of translating the compliance and training materials
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