The Criminal Division of the US Department of Justice recently updated its guidance document for the "
Evaluation of Corporate Compliance Programs."
Does your company's compliance program satisfy the guidance - get a compliance audit to find out ASAP.
To satisfy the guidance, your company needs to:
- Address risk assessment, including constant updates and revisions;
- Offer accessible policies and procedures;
- Train and communicate;
- Investigate with a confidential reporting structure;
- Address / train / evaluate its third-party partners, like agents, consultants, and distributors; and
- Evaluate targets' exposure before merging or acquiring.
This guidance particularly matters because " United States Sentencing Guidelines advise that consideration be given to whether the corporation had in place at the time of the misconduct an effective compliance program for purposes of calculating the appropriate organizational criminal fine."
