Carlo V. di Florio, who is the Director of the SEC's Office of Compliance Inspections and Examination, offers up an essay on "two related topics that are growing in importance: the heightened role of ethics in an effective regulatory compliance program, and the role of both ethics and compliance in enterprise risk management," with three major take-home points:
1. Ethics is fundamental to the securities laws, and I believe ethical culture objectives should be central to an effective regulatory compliance program.
2. Leading standards have recognized the centrality of ethics and have explicitly integrated ethics into the elements of effective compliance and enterprise risk management.
3. Organizations are making meaningful changes to embraced this trend and implement leading practices to make their regulatory compliance and risk management programs more effective.
