Fcpa Compliance Report

Yesterday I began a two-part series on the Department of Justice (DOJ’s) “Evaluation of Corporate Compliance Programs” (Evaluation) posted on the Fraud Section in February. The document is an 11-part list of questions which encapsulates the DOJ’s most current thinking on what constitutes a best practices compliance program. Within the list are some 46 different questions that a Chief Compliance Officer (CCO) or compliance practitioner can use to benchmark a compliance program. In short, it is an incredibly valuable and most significantly useful resource for every compliance practitioner. Three Key Takeaways This DOJ Evaluation provides clear guidance on the expectations of government regulators regarding what your program should consist of, how it should be effected and where you need to go down the road. It is also a valuable teaching tool as you can lay out for your Board and senior management the clear requirements for any best practices compliance program. The document also re-emphasizes that you should