Erica Salmon Byrne (erica.salmonbyrne@ethisphere.com) is the Executive Vice President of The Ethisphere Institute.

It seems like a perennial question: How should our program be structured? Of course, when it comes to ethics and compliance, there are no hard-and-fast rules on program structure—something that regulators around the globe have long recognized. The most recent example of this can be found in the April 2019 Department of Justice (DOJ) guidance issued by the Fraud Division,^[1] which asks, “Is the program well designed?” but does not specifically define what this entails, leaving room for interpretation based on an organization’s assessment of risk. When we think about this question, we look at overall structure and how responsibility for compliance oversight is assigned.