So where does a "culture of compliance" come from?

Given that 36 percent of the employees who commit fraud come from corporate finance, it makes sense that the CFO should take the lead in making sure compliance activities are accorded appropriate weight across the organization. The notion that companies need to get more serious about compliance has taken on added urgency in light of new regulations, heightened enforcement of the Foreign Corrupt Practices Act and various whistleblower-friendly developments.

But setting the tone at the top is often difficult, even for executives that really want to do the right thing. As CFO magazine notes, "changing a company's culture is extremely difficult, and often requires senior executives to untangle delicate in-house politics, agitate profitable operations overseas, and relentlessly police the entire organization's compliance program. No single e-mail or ethics training course will achieve that." The article offers 5 pieces of advice for CFOs who want to get started on this.           

1. Acknowledge that you are responsible. If you do not own the problem, who else will?
2. Make the corporate counsel your ally. You just might need some legal firepower to make your initiatives stick. While the finance employees wield carrots, the legal guys wield sticks. So you need their buy in.
3. Really deliver the message. The CFO and CEO need to talk to the internal communications folks about how to underscore the imperative. A single day of training and some posters in the lobby will not do the trick.
4. Educate front-line managers. You want to get a grip on this problem at the front line. Managers need to understand the importance of this and what their responsibilities are. They all have some watchdog and deterrent responsibilities whether they know it or not.
5. Simulate a crisis. Walking through possible crime scenarios might go a long way toward plugging holes and addressing risks before it's too late.

 For more:
- here's the article

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