Which of the following is NOT required for an effective compliance program?

An effective compliance program is built on several key components that enable organizations to detect and address compliance issues effectively. One crucial element is the establishment of effective lines of communication, which facilitate the sharing of important compliance information among staff and management. Additionally, having well-publicized disciplinary standards ensures that employees understand the importance of compliance and the consequences of violations, which helps foster a culture of accountability.

Moreover, a prompt response to compliance issues is essential because it demonstrates an organization's commitment to addressing risks and making necessary improvements.

While having legal counsel review policies can certainly enhance the quality and reliability of compliance-related documents, it is not explicitly required for a compliance program to be deemed effective. Organizations may have robust compliance programs with effective training, monitoring, and communication without necessitating prior legal counsel approval for every policy. Therefore, this aspect is not a mandatory component of an effective compliance program, distinguishing it from the other elements that are vital for ensuring compliance and embedding a culture of adherence within the organization.