In this episode of the RANE Insights series, a look at recently revised U.S. Department of Justice “Evaluation of Corporate Compliance Programs” guidance.
By asking questions in three key areas, prosecutors try to understand the reasons for how the compliance program was set up and how the program has evolved over time:
1) Is the corporation’s compliance program well designed?
2) Is the program adequately resourced and empowered to function effectively?
3) Does the corporation’s compliance program work in practice?
The revised guidance can be found here:
https://www.justice.gov/criminal-fraud/page/file/937501/download
RANE has a number of experts in our network who can help assess your compliance program in light of the most recent changes.