Miller, G. P. (2014). The compliance function: an overview. Flashcards
What is the primary purpose of the corporate compliance function?
To ensure that firms and their employees obey applicable laws, regulations, and norms through internal monitoring and control — effectively acting as a form of internalized law enforcement.
What are the “Three Lines of Defense” in corporate compliance?
- Operating units (line staff and managers)
- Compliance & risk officers (monitoring and guidance)
- Internal audit (independent oversight)
Other oversight actors include boards, external auditors, and regulators.
Why has the compliance function become so important?
Due to the rise of the administrative state, globalization, and increased liability exposure, firms now face greater pressure to proactively prevent legal and ethical violations.
What are key elements of a robust compliance program?
Clear policies, strong “tone at the top,” employee training, risk assessments, monitoring, whistleblower protections, and independent audit functions
What is “compliance beyond the firm”?
Firms are now expected to enforce legal and ethical standards in their supply chains, business partners, and global operations — e.g., conflict minerals reporting and anti-bribery compliance