kaal:claim:2486570-027

Generic industry advice on building an effective compliance program cannot work in practice because it is written to apply to many firms at once while no two companies are sufficiently alike for general guidance to be effective.

is necessarily mostly general because the advice is meant to apply to a multitude of companies. However, in practice, no two companies are sufficiently alike to effectively provide general guidance on compliance programs.

Wulf A. Kaal, Timothy Lacine, The Effect of Deferred and Non-Prosecution Agreements on Corporate Governance Evidence from 1993-20 (2014), VI.B. IMPLICATIONS FOR BOARDS, MANAGEMENT, AND LEGAL COUNSEL, p. 56
https://ssrn.com/abstract=2486570 · source PDF

Wulf A. Kaal, Timothy Lacine, The Effect of Deferred and Non-Prosecution Agreements on Corporate Governance Evidence from 1993-20 (2014). SSRN: https://ssrn.com/abstract=2486570

failuresupport: arguedfailure: generic-compliance-advice-failsfamily: compliance-cost-and-barrier-to-entrycompliance

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