BC Advantage - 2017 Issue 6

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:Analysis and Remediation of Underlying Conduct: What is the organization's root cause analysis of the misconduct...

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