“GOAT” compliance programs

7 minute read

I have always loved to compete in sports, even though I have been consistently mediocre. In contrast, I like to watch sports because I like watching the Greatest Of All Time—a.k.a. the “GOAT.”

People will always debate about the GOAT in each sport. Tom Brady, with seven Super Bowl victories, is a great candidate for football. Serena Williams has won 23 major singles titles, dominating women’s tennis for the last two decades. My personal all-time favorite is Earvin “Magic” Johnson, who won five NBA titles in basketball in the 1980s. Each checked many boxes: they had great technique and intangibles, worked to improve aspects of their craft in the off-season, and had solid overall game IQ. All have at least one thing in common: results. They won—a lot—at the highest levels of their respective sports.

What about the gold standard in anti-bribery/anti-corruption (ABAC) compliance programs? What makes a program the GOAT? Whatever the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) demand of companies? The DOJ/SEC guidance in the last decade should be part of every compliance program because, as we will explore, it sets a standard. However, continuous monitoring—which includes regularly conducting third-party audits—is also necessary for GOAT status and, more importantly, to detect and prevent corrupt activity.

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