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ARTICLE · 27 MARCH 2026

Effective Compliance Management Systems: Core Elements For Every Business And Industry

Over the decades, the FTC has clarified that companies of all sizes are expected to create and implement a compliance management system (CMS) tailored to their size, complexity and risk profile. A CMS is a "must-have" – not discretionary – as regulators require companies to have one as part of their business model.

United StatesConsumer Protection

Highlights

  • The Federal Trade Commission (FTC) is the nation's primary consumer protection agency, with a mission to protect the public from deceptive or unfair business practices, as well as unfair methods of competition.
  • Over the decades, the FTC has clarified that companies of all sizes are expected to create and implement a compliance management system (CMS) tailored to their size, complexity and risk profile. A CMS is a "must-have" – not discretionary – as regulators require companies to have one as part of their business model.
  • This Holland & Knight alert identifies the core elements of such a system, drawing on the frameworks established by the FTC, Consumer Financial Protection Bureau, U.S. Department of Justice, other federal agencies and state attorneys general enforcement actions.

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