This global survey of senior legal and compliance professionals shows that stronger legal enforcement and pressure from regulators with extraterritorial reach – as well as the evolution of local corruption laws – are persuading companies based around the world to improve their standards of compliance across all markets. However, compliance programmes have failed to keep pace with the legislation. For many organisations, this produces a dangerous gap between the perceived effectiveness of a programme and the reality on the ground.
Overreliance on compliance is dangerous. Just as people drive faster when wearing a seatbelt, so compliance programmes can lead to a false sense of security. Programmes that are unfocused, incomplete or poorly implemented encourage companies to make decisions without a proper appreciation of the specific risks that they face, or the activities their operational teams on the ground are involved in. There is no point admiring the instruments on your shiny compliance dashboard if you’re not watching the road ahead – and not checking your blind spots.
This is why companies with compliance programmes can still find themselves grappling with serious corruption, often uncovered in a remote office. Programmes driven from head office are overly focused on policies and training, but these alone will not be effective at mitigating corruption risks. Those procedures that have the most potential to enhance understanding of corruption risk at an operational level – due diligence, monitoring and auditing – are not being performed effectively, early enough, or at all.
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