The DOJ/SEC has, in its Resource Guide, set out ten "Hallmarks of Effective Compliance Programs" that the agencies may consider in ascertaining whether a company's FCPA compliance program is effective. Which of these hallmarks do you think are the most important in practice? Which of the hallmarks do you think companies might find most challenging to implement? Do you think anything is missing from the current list, or that anything currently included in the list could be usefully removed