Brown advises senior managers to help their firms avoid that fate by giving attention to the following four areas:

1. Reinforce Lawful Business Conduct and Effective Internal Controls. Senior managers should meet with their compliance officers and internal auditors to reassess compliance and control risks in light of the demands created by the financial crisis.

Chief executives and chief financial officers should directly communicate as a component of all business goals the need to maintain effective internal controls and legal-compliance systems. Compliance and ethics Web sites should be updated and effective employee and third-party training should continue.

2. Avoid 'Short-hand' Communications that Signal Less Commitment to Compliance and Internal Controls. During a crisis, managers often provide "short-hand" instructions without realizing that they may be a signal of lessened commitment to legal compliance and adherence to internal controls.

Risky statements can include: "Just get it done." "Do not bother me with the usual details." "We can't survive without this." "You don't need to run it by legal." "We must get this deal." or "Pay this without Tom's signature because he is busy with the crisis work team."

Employees under pressure may interpret these as allowing evasion of internal controls. Careful instructions will decrease legal risks for managers and the firm.

3. Continue Audits, Particularly in High-Risk Areas. Do not defer financial and compliance audits. A scheduled compliance audit will create positive, competing pressures for employees to remain vigilant.

Audits should measure compliance with procedures for payments, recordkeeping and accounting in the following areas: business development and promotions; procurement; donations, interactions with officials (including entertainment, gifts, travel, product demonstrations); vendor and supplier contracting; agent hiring; merger and acquisition due diligence; customs; and overseas taxes.

4. Quickly Investigate Misconduct. Problems are exacerbated when employees ignore indications of an internal-control breach or a violation of law. Prompt investigation of suspected violations of law, policy or internal financial controls is still required.

Appropriate remedial measures, including possible disclosures, must be undertaken.

Recognize that overworked lawyers and financial/compliance personnel become enforcement targets (along with the company) when they fail to take timely action involving a suspected violation of law or internal controls.