# Compliance programs

`kaal:entity:compliance-programs`

**Status.** derived

This node is assembled mechanically from the 5 claims that carry the concept tag `compliance-programs`. It is a roster of what the corpus says under this term. It is **not** an adjudicated definition: no single statement here has been ruled canonical, and no first-appearance call has been made. Read the claims and judge for yourself.

## Every claim under this term

5 claims across 2 works, 2013 to 2014.

**2013**

- [2317580-004](https://wulfkaal.github.io/claims/2317580-004) [definitional/asserted] -- Corporate Integrity Agreements are a hybrid instrument: they are compliance programs funded by health care companies but administratively enforced by the government, that is, contracts between health care companies and the federal government carrying costly mandatory compliance measures and penalties.
  > CIAs are administratively-enforced compliance programs funded by health care companies but enforced by the government. In other words, they are contracts between health care companies and the federal government and can involve costly mandatory compliance measures and penalties.
  Wulf A. Kaal, Elizabeth R. Malay, The Role of Corporate Integrity Agreements in the Expansion of Fiduciary Duties (2013). SSRN: https://ssrn.com/abstract=2317580

**2014**

- [2486570-006](https://wulfkaal.github.io/claims/2486570-006) [failure/argued] *(failure mode)* -- Existing corporate criminal liability combined with the absence of clear Department of Justice standards for charging businesses can push organizations to adopt unproven compliance programs and generate other inefficiencies.
  > The existing corporate criminal liability in combination with a lack of clear DOJ standards for charging businesses may also lead organizations to adopt unproven compliance programs and create other inefficiencies.
  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
- [2486570-015](https://wulfkaal.github.io/claims/2486570-015) [empirical/evidenced] -- Waiver of rights provisions are the most prevalent governance term in the sample, appearing in 96 percent of agreements, followed by cooperation with the government at 91 percent and improved compliance programs at 75 percent.
  > Ninety-six percent of the sample con- tained waivers-of -rights provisions, 91 percent cooperation with the government provisions, and 75 percent improved compliance programs.
  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
- [2486570-019](https://wulfkaal.github.io/claims/2486570-019) [empirical/evidenced] -- Although 45 percent of sampled agreements required improved communication and training, only 11 percent required the entity to create the position of chief compliance officer, so the most structural compliance remedy is the rarest.
  > Only 11 percent of the N/DPAs in our sample required the creation of a chief compliance officer.
  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
- [2486570-027](https://wulfkaal.github.io/claims/2486570-027) [failure/argued] *(failure mode)* -- 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). SSRN: https://ssrn.com/abstract=2486570

## Verify

Every claim above resolves to a record carrying a verbatim source quote, the sha256 of the source PDF, and a preformatted citation. Nothing here asks to be taken on trust.

    curl -s https://wulfkaal.github.io/entities/compliance-programs.md | sha256sum

**Canonical form.** This markdown file is the canonical hashed representation of this entity node. Its sha256 is the content hash.