Corporate Compliance

Blaine Smith   February 28, 2017   Comments Off on Corporate Compliance


The DOJ Fraud Section’s “Evaluation of Corporate Compliance Programs” puts chief compliance officers on notice about how the adequacy of their companies’ compliance programs is evaluated by prosecutors.

On February 8, the Fraud Section of the US Department of Justice (DOJ) published a list of “important topics and sample questions” it uses when evaluating the effectiveness of corporate compliance programs-titled “Evaluation of Corporate Compliance Programs”. [F/N1]

The Compliance Program Guidance is divided into 11 sections:

(1) Analysis and Remediation of Underlying Conduct
(2) Senior and Middle Management
(3) Autonomy and Resources
(4) Policies and Procedures
(5) Risk Assessment
(6) Training and Communications
(7) Confidential Reporting and Investigation
(8) Incentives and Disciplinary Measures
(9) Continuous Improvement, Periodic Testing and Review
(10) Third Party Management
(11) Mergers & Acquisitions