The Italian Organismo di Vigilanza, A Model for an Effective Compliance Committee

As anti-corruption enforcement continues to expand around the globe, companies have much to learn from the way organizations operating in other regions approach compliance. In Italy, companies can avoid anti-corruption liability by adopting effective compliance standards and controls including a compliance committee called an Organismo di Vigilanza. According to the best practices and guidelines issued by relevant industry associations, a company’s Organismo di Vigilanza, in combination with company leadership, should be responsible for the supervision of the company’s compliance program, preventing prohibited behaviors and for reviews, updates and training. In a guest article, Aurelio Giovannelli and Roberto Cursano – partner and counsel, respectively, at Baker & McKenzie’s Studio Professionale Associato in Rome – discuss the laws governing the Organismo di Vigilanza and how to form such a committee. See also “Regional Risk Spotlight: Baker & McKenzie Lawyers Discuss Italy’s Corruption Risks and Unique Compliance Model” (Apr. 20, 2016). 

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