Adopting compliance programs to address corporate culture issues is not enough to enforce the value of internal compliance efforts. Although federal enforcement officials have warned that corporate compliance comes with a price tag, non-compliance affects the entire organization from a broader perspective.
After Facebook's record-setting settlement with the Federal Trade Commission in July over its misuse of user data, the social network must now restructure its privacy operations further than just compliance.
"They obviously had a defective tone at the top," said Attorney Mitchell Herr, who spoke at the Florida Enforcement Summit hosted by Holland & Knight, and corporate culture was a theme in the compliance discussions.
"Eight of ten whistleblower complaints received by prosecutors were delivered by employees because their companies didn't listen to them. They were ignored, fired or just swept to the side, said Attorney Wifredo Ferrer, who moderated the Summit panel that focused on minimizing risks in light of enforcement priorities.
The panelists also emphasized self-reporting and also stressed to acknowledge existing problems, to try to resolve them and report them to government agencies.
READ: Don't Think About Profits When Weighing Compliance, South Florida Feds Warn (Subscription required)
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