When following policies regarding corruption such as bribery, extortion, money laundering and fraud, it is important that those doing the investigations as well as the companies involved in detecting and tracking suspected corrupt behavior, consistent compliance is such an important aspect of the battle, but sometimes an aspect that is difficult to maintain. The requirements are specific, but even still they are sometimes not followed thoroughly.
As with any activity that requires a constant and diligent effort, learning to surf or learning to play the cello, the only way to ensure a proper return, meaning success, is to be consistent on a daily basis. For companies with regards to the requirements set upon them for their responsibility for fighting terrorism the consequences of not remaining consistent are far greater that that for the aspiring cello player or surfer. For a lax approach to following all of the laws, companies or organizations may be held responsible for criminal actions themselves.
They risk penalties, fines, prosecution and the loss of either business or the company entirely. However, if a company can show that they have been compliant, consistently so, they will not be held liable. The best way to maintain the constant compliance of employees is simple. Compliance is rewarded while non compliance is punished. This may seem to be common sense, however it is written as advice in the Sentencing Guidelines manual itself.
The guidelines suggest ideas such as incentive programs that reward thorough and complete performance with regards to ethical business practices, and they offer advice on the disciplinary actions that are appropriate for the various levels of failing to take steps in the detection and the prevention of those criminal activities. There are also suggestions on the course to take when the employee themselves is involved in the criminal behavior. The guidelines allow leeway with the company for the creative solutions they come up with in order to deal with errant behavior of an employee, as well as their own creative ideas with regards to the incentive programs in regards to performance of an exemplary nature.