SEC Chief of Staff Andrew J. Donohue shared professional insights he acquired during his forty years of experience in legal and corporate compliance. Mr. Donohue emphasized the following ways to help maintain effective corporate compliance programs:
- utilize people of integrity who accept personal responsibility for corporate compliance programs;
- maintain a culture dedicated to “always doing the right thing” and “not tolerating bad practices or bad actors”;
- ensure the correlation between ethical behavior and reward structures within the firm;
- simplify policies and procedures by making them as clearly applicable and intuitive as possible;
- harness technology in order to ensure compliance, but maintain personal responsibility for any errors that may occur;
- identify the blind spots that can occur in compliance programs when firms implement increasingly complex operations, products and services; and
- continually ask what compliance programs and officers might be missing.
Mr. Donohue delivered his remarks in a speech at the Rutgers Law School Center for Corporate Law and Governance.