Imagine that you are the chief compliance officer for an international stock brokerage firm. You are asked to meet with the board of directors of the firm to provide suggestions that will enable the firm to ensure that employees comply with the firm's compliance programs.

How will the standard articulated by the courts in Caremark and Citigroup inform your recommendations?

Does this standard require the board of directors or the chief compliance officer to be aware of every violation of the firm's compliance policies?

How diligently should the board of directors and executives police employee activities?

Should shareholders expect the board and compliance professionals to identify wrongdoing that happens: a) rarely; b) periodically, or c) frequently?

Should it matter if the actors frequently accused of wrongdoing are rankinfile employees or executives?

What specific policies will you recommend to help ferret out wrongdoing by employees who work in the firm's ten offices located around the world?