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062513_Biskup Cameron_photosAs regulations continue to evolve in jurisdictions around the world, corporate boards and senior managers are paying very close attention to compliance efforts enterprise-wide. Organizations are reviewing procedures across business units and geographic boundaries to improve visibility into their regulatory compliance and mitigate compliance risks. In this process, though, treasury departments often get short shrift.

Deloitte recently published a book titled “Enterprise Compliance: The Risk Intelligent Approach.” Treasury & Risk sat down to discuss the book, and treasury’s role in enterprise compliance, with two of the firm’s thought leaders: Robert Biskup, director of forensic and dispute services, and Melissa Cameron, a Deloitte principal who specializes in treasury. Biskup previously served as the chief compliance officer for a Fortune 10 company, and Cameron served previously as a corporate treasurer and a wholesale banker. Both see the treasury function as a key, and often neglected, player in corporate compliance efforts.

T&R:  More than a decade after the Sarbanes-Oxley Act brought regulatory compliance to the forefront for corporate boards and management, how well are most businesses doing in the area of compliance?

062513_Biskup Cameron_PQ1Robert Biskup:  The past 15 years have been a very dynamic period of development in corporate compliance programs. In the pre-SOX [Sarbanes-Oxley] era, companies that weren’t in highly regulated industries, such as defense or financial services, commonly had compliance programs that consisted of a vision statement and little else. I think of that as the first generation of corporate compliance programs. Then, post-SOX, a lot of corporations started doing a good job of enhancing their vision statements; publishing robust codes of conduct; expanding their policies and procedures; and enacting everything that SOX specifically called for, including whistle-blower and incident-management programs. But despite these proactive aspects of compliance, some of the back-end aspects—around assurance, auditing, monitoring, things of that nature—were lagging. I think what we are seeing now is the unfolding of the third generation of corporate compliance programs. Companies have spent 15 years in an incubation period, filled with trial and error and experimentation. Now they have a better understanding of what the effective elements of a compliance program ought to look like.

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