Among my earliest memories as an internal auditor was the constant refrain from officials in my organization that, as internal auditors, our job was to keep them “out of jail.” It was their light-hearted way of signaling how important we were to them. I didn’t take them too seriously, because I didn’t know of too many people who went to jail because of an internal control or compliance failure. But, as Bob Dylan so famously sang, “the times they are a-changin’!”
The recent guilty plea by a former drug company compliance officer on conspiracy and other charges is yet the latest example of when willful compliance failures can lead to jail time for executive management.…