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Program Structure

In the posts collected here we will discuss assessment-related issues concerning a) various types of C&E program roles and reporting relationships, including those involving the board of directors; senior management; C&E department management; other staff, such as members of the

Assessing Codes of Conduct

Codes of conduct are often described as the most important document in a compliance program. Codes help set the right tone for compliance and ethics (“C&E”) programs.  They are educational tools that should serve to raise awareness and understanding of

Revisions to DOJ Program Evaluation Guidance

On June 1, 2020, the U.S. Department of Justice (“DOJ”), Criminal Division, updated its guidance on the “Evaluation of Corporate Compliance Programs” (“the  2020 Update”) to provide increased clarity on several of the key questions prosecutors might ask in assessing

Legal Guidance related to Program Assessment

Legal guidance in the area of C&E program assessments accords with professional wisdom in this area, emphasizing the importance of periodic assessments to an effective program. In this post, we review a few of the relevant legal standards from U.S.

PLI One-Hour Briefing on Compliance & Ethics Program Assessment

On September 28 at 1:00 Eastern Rebecca and Jeff will be leading a One-Hour Briefing for the Practising Law Institute on C&E program assessment. The program will cover: Official requirements for conducting C&E program assessments and business-related reasons to do

Audit Interviews Regarding Employee C&E Knowledge

An often useful but not always used self-assessment tool is to include in an audit interview questions to determine if employees have sufficient knowledge of C&E program requirements and resources. Knowledge questions – as these might be called – are

Assessing risk assessment

When the Federal Sentencing Guidelines for Organizations were first issued in 1991, risk assessment was not among the specified elements of an effective C&E program. By the time risk assessment was added to the definition of an effective C&E program

  • Assessment mandates and benefits
  • Methodologies
  • Risk assessment
  • Program structure
  • Standards and procedures
  • Training and communications
  • Auditing, monitoring, and other “checking”
  • Reporting procedures, including helplines
  • Investigations
  • Discipline and other remedial measures
  • Personnel measures
  • Culture
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