One of the most clear-cut lessons to take away from the federal government’s $77 million penalty Thursday against Zurich-based Credit Suisse Group AG is that general counsel must “operationalize” their companies’ compliance policies.
“It is not enough to have a global statement on paper barring something,” said attorney Julie Myers Wood, CEO of Guidepost Solutions, an investigations and compliance consulting firm with offices in New York and Washington, D.C. “General counsel have to think about how those policies will be carried out, and about training all the people who control functions to execute on the policies.”
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