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January's Feature Article

January's Feature Article
Creating a Compliance and Ethics Program from Scratch
Congratulations! Your company has recognized the need for a dedicated compliance and ethics function and you have been chosen to lead it. You have three months to present a plan of implementation to the company's audit committee. You marshal resources, order a review of company policies, investigate how your foreign intermediary was on-boarded, pay top dollar to several technology providers to provide you with compliance tools, and start off the compliance and ethics function. At the end of the second month, you realize that each action item you undertook has opened up a Pandora's box and that you are at a loss as to what to report to the audit committee.