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Bernie Madoff died yesterday. I cannot think of one person who embodied so many of the things that the compliance profession stands against than Madoff. From fraud, to lying, to ruining lives and about everything in between; it was all wrapped up in Madoff. Given the complete failure of the Securities and Exchange Commission (SEC) to shut Madoff down after whistleblower Harry Markopolis alerted authorities to the massive fraud, I thought the fall of Madoff would be a good introduction into some best practices regarding an internal reporting system. The 2020 FCPA Resource Guide stated, “An effective compliance program should include a mechanism for an organization’s employees and others to report suspected or actual misconduct or violations of the company’s policies on a confidential basis and without fear of retaliation.”