Internal compliance investigations can reduce government sanctions.
An effective corporate compliance program is facilitated by three essential elements: a well-qualified compliance officer; a policy of immediate investigation of every report of potential fraud and abuse; and clearly defined roles for both corporate and outside counsel in conducting the investigations. A government agency is less likely to exercise the full extent of its powers when these elements are in place and three is evidence of a sincere compliance effort.
Mustokoff
M M
MM
Duane, Morris and Heckscher LLP, Philadelphia, PA, USA.
Yecies
M S
MS
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