On October 7th, SEC Associate Director of Enforcement, Stephen L. Cohen, discussed the importance of a robust compliance program and the hallmarks of such a program. Using the Commission's recently released Foreign Corrupt Practices Act resources guide as an example, Cohen noted the benefits of a strong compliance culture. He remarked that "the better the compliance program, the less likely we may charge the parent company for acts of a subsidiary." The strength of a firm's compliance program will also affect the penalty which the SEC may seek. Cohen Remarks.