DOJ's Newest Evaluation Criteria for Investigating Compliance Programs

The Department of Justice (DOJ) recently published a guidance document titled "Evaluation of Corporate Compliance Programs" that provides insight into how the Fraud Section evaluates compliance programs under criminal investigation.  This guidance emphasizes the government's commitment to fighting corporate fraud under the former Deputy Attorney General Yate's memorandum and serves as a valuable tool to measuring your organization's compliance program's effectiveness.

Here is a summary of the topics and questions that the DOJ finds relevant when evaluating a corporate compliance program under investigation:

Remember, maintaining an effective compliance program is an ongoing process that does not stop with taking any one particular action, such as having a binder of compliance policies or one-time training session. A proactive approach is key in ensuring your organization has a program in place that will deter, detect and prevent noncompliance. Review the full guidance document here to see if your organization has the proper internal controls to withstand government scrutiny.  

Sheba Vine, JD, CPCO - 1sthcc