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Tests for "effective" compliance programs take the form of lists specifying required elements in varying level of detail. From an economic perspective, an effective compliance program can be defined more fundamentally as the set of policies and procedures that a rational, profit-maximizing firm would establish if it faced an expected sanction equal to the social cost of violations. This paper explores the idea and several of its extensions and qualifications.doi:10.2139/ssrn.2533661 fatcat:ixhewy53vvhn5ja4slyuq3va2e