What Every Multinational Company Should Know About . . . Implementing An International Compliance Program (Part II)

In our prior update (published November 29), we provided the first five steps in our twelve-step program for international compliance. These steps are intended to help companies identify international regulatory risk inherent in their international operations. By carefully working through these twelve steps, most multinational organizations should be able to implement the kinds of compliance that U.S. regulators would consider compliance best practices, including in the newly emphasized area of supply chain due diligence and compliance.

Step 6: Create a Written Compliance Policy

It is unfortunate that Step 6 — the drafting of the compliance manual — is often Step 1 for many companies. As shown in our prior update, however, there is considerable groundwork to cover before an organization should begin the actual drafting of the compliance manual.