Compliance programs are a novel approach of preventing corporate crimes compared to traditional
countermeasure of preventing corporate crimes through aftermath punishment. However, due to its
astronomical expenditure, there must be a suitable reward to encourage the implementation of an
effective compliance program. This article compares the American and German approaches of
incentivizing compliance and their respective developments in order to answer the questions: how
should an effective compliance program be rewarded, and should corporate accountability or
individual accountability be the basis of compliance rewarding mechanisms?