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Government attention to corporate compliance, ethics and governance has vastly increased over the last few years. Massive corporate scandals such as Enron, MCI and others, combined with ongoing fraud and abuse enforcement in the health care and government contracts industries, have created a 'perfect storm' of civil and criminal enforcement. The result has been an alphabet soup of acronyms, programs and initiatives suggesting, encouraging, cajoling and, in many cases requiring formal, written codes of ethics and business conduct. Extensive compliance programs, internal control systems, training, auditing and other activities have, in some instances, been imposed on already heavily regulated industries.
This article endeavors to make sense of these standards and provide some practical advice on to best protect your company by focusing on the one common thread found in virtually all of the new statutory, regulatory and enforcement guidance: 'Risk Assessments.'
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