Fortunately, not every organization will face a major compliance scandal. This does not mean, however, that otherwise healthy firms cannot benefit from a compliance culture. The purpose of this assignment is to evaluate an otherwise functioning organization from a compliance perspective. The purpose of this assignment is to evaluate the effectiveness of the firms ethics and compliance programs. I recommend (but do not require) choosing a large and publicly traded company for this assignment. The alternative is to select your hypothetical company. In that way you will most likely have sufficient public information with which to write a suitable paper. However, if you have a firm with whom you have a specific relationship or specific knowledge, you may choose to write about that company after first obtaining my approval. The goal of this project is not simply to summarize compliance. Only summarize the firms compliance function as is necessary, and do not go into unnecessary length summarizing what the compliance function is and does. Rather, this paper must evaluate the firms compliance function for its strengths and weaknesses, citing specific features of the firms compliance program as well as specific examples of where the firm has displayed success or problems. In other words, put yourself in the position of a compliance manager (not a CCO or CEO), and present a proposal of how you would change the compliance function to add value, reduce risk, and build a culture of integrity. This paper could evaluate various aspects of compliance, including regulatory compliance, compliance processes, and organizational structure of the compliance function. This paper could also evaluate business ethics, corporate responsibility, management of legal risk, sustainability, and/or human rights as they relate to the compliance function. Do not attempt to cover all facets of compliance at once. It is preferable that you focus on one or two aspects of a firms compliance function in depth rather than try to cover the entire function 8 superficially. This promotes a deeper analysis and a more complex expression of your understanding of compliance. The paper must also include recommendations for reform and improvement of compliance. No firm is perfect, and the paper should contain concrete and realistic proposals that the firm should implement to improve their compliance. Budgets are tight and no firms resources are unlimited, so the paper should take cost and feasibility into account when making such recommendations. This paper is individually written, and must be no longer than six (6) thoughtful and analytical double-spaced pages (excluding references and appendices). Make each sentence count. Avoid unnecessary introductions, summaries, or block quotations.
