The Fraud section of the U.S. Department of Justice has published a list of “important topics and sample questions” it uses when evaluating the effectiveness of corporate compliance programs – entitled “Evaluation of Corporate Compliance Programs.” It is the first formal guidance issued by the Fraud section since the change in the U.S. presidential administration and confirmation of the new U.S. attorney general.
While the Evaluation Guidance does not necessarily break new ground, it advances the DOJ’s oft-stated commitment to periodically delivering meaningful guidelines for companies with respect to its expectations for effective compliance programs. With its emphasis on specific topics and explicit program assessment questions, the Evaluation Guidance expands upon the valuable compliance program information contained in both Step 3 of the FCPA Pilot Program and the section entitled “Hallmarks of Effective Compliance Programs” in A Resource Guide to the U.S. Foreign Corrupt Practices Act. To date, it represents the most universally applicable and clearly articulated statement of the Fraud Section’s primary focus areas when determining the efficacy of corporate compliance programs.
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