Last month, Leslie R. Caldwell (Assistant Attorney General for the Justice Department’s Criminal Division) spoke at the 22nd annual Ethics and Compliance Conference. She discussed a variety of topics, but focused specifically on the importance of having a comprehensive compliance program in place for every organization.
She primarily focused her discussion on the implementation of a general corporate compliance program, but the same principles can be applied to an export compliance program. While there is no one-size-fits-all approach to export compliance, the following should provide some guidelines to consider when deciding upon the appropriate program for your company.
