Perfect Is the Enemy of Good

Anti-corruption compliance efforts that don’t prevent every instance of governance lapse are not failures. Compliance professionals know this. So do federal regulators and prosecutors, but risk managers, general counsel, board members and residents of the C-suite too often do not. Richard Cassin, writing in the FCPA blog, says they could save themselves and their compliance officers a lot of aggravation if they internalize the simple fact that perfection is unattainable. Compliance officers, for their part, should lay out real versus unreal expectations. Guidance to prosecutors from the DOJ’s Evaluation of Corporate Compliance Programs states that “the existence of misconduct does not, by itself, mean that a compliance program did not work or was ineffective,” and recognizes that no compliance program “can ever prevent all criminal activity by a corporation’s employees.” Guidance for compliance requires a program that can help prevent violations, and if they happen, can help detect, remediate, and report them.