Do your compliance programs check the boxes?

DOJ Guidance on Evaluation of Corporate Compliance Programs: Key Takeaways

Eoin Hudson News, Other, Research

Quick take: as investigations increase, ways in which a company can further safeguard against potential prosecution and negative judgments are particularly valuable.

Hyperproof summary: prosecutors were issued expanded guidance by the US Department of Justice in April for evaluating the effectiveness of corporate compliance program in the case of an investigation. This guidance should be used by companies to ensure their programs align with the DOJ’s expectations, because they determine whether a company has demonstrated commitment to compliance and deserves settlement credit.
 
The article distills these new guidelines into three fundamental questions:

    1. Is the compliance program well designed?
      Is the risk profile identified, defined, and assessed?
    2. Is the program being implemented effectively and in good faith
      Has a commitment to compliance been demonstrated by senior and middle management?
    3. Does the compliance program work in practice
      Are issues identified, resources available, remediation efforts thorough?

 

Read the full article here