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Measure Twice Cut Once

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November 10, 2021

Richard Cassin, writing in FCPA Blog, asks the following question: If management is about math, what does that mean for managing compliance? By “math” he means measurement, and although there are elements of compliance and training that can be measured, the key issue, employee intent, is not measurable because it’s invisible and can change in an instant. The fact is, when employees face real-world choices whether to comply or cheat you can’t know what will happen. Nevertheless, Cassin advises compliance managers to keep measuring the two things they can quantify: 1) How much training is done, and 2)how effective it’s been, which can be measured by testing. For what it’s worth, the DOJ offers more or less the same advice in chapter 8 of its sentencing guidelines. Cassin stipulates that the adequacy and effectiveness of compliance programs are partly what compliance managers can defend and partly what the feds say it is. “That’s a double tautology,” he admits, but do your best anyway.

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