BC Advantage - 2017 Issue 6
DOJ's Newest Evaluation Criteria for Investigating Compliance Programs
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Article Overview
This article covers the DOJ’s updated approach to evaluating corporate compliance programs in the context of criminal investigations. It is useful for compliance leaders, legal teams, and organizational management who want a high-level understanding of the categories of questions the government may consider when assessing program effectiveness, including governance, resourcing, training, reporting, discipline, third-party oversight, and mergers and acquisitions.
Why This Topic Matters
Understanding the DOJ’s evaluation framework helps organizations gauge whether their compliance program is mature, documented, and responsive enough to withstand government scrutiny. The article provides a practical overview of the major review areas that matter to compliance, legal, and executive stakeholders.
Article Sections
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Overview of DOJ guidance on corporate compliance programs
Introduces the Department of Justice guidance and explains its role in assessing corporate compliance programs during investigations.
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Evaluation topics and review questions
Summarizes the major subject areas and questions the DOJ considers when reviewing program effectiveness, including governance, risk management, training, reporting, and remediation.
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Ongoing program effectiveness and continuous improvement
Highlights the importance of continuous monitoring, periodic review, and sustained improvement as part of an effective compliance program.
What You Will Learn
- How the DOJ frames its evaluation of corporate compliance programs
- Which broad compliance program components are commonly reviewed
- Why documentation, oversight, and remediation are emphasized in government scrutiny
- How continuous improvement fits into compliance program effectiveness
Who Should Read This
- Compliance officers
- Healthcare compliance professionals
- Legal departments
- Corporate risk management teams
- Executives and board members
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