Compliance Program Assessment Blog
Training the Board
Although many companies have well-developed procedures and practices for reporting information to their boards regarding their compliance and ethics...
More on reverse conflicts of interest
A company enters into a complex business arrangement where one of its managers has a relationship with the other entity. The relationship is fully disclosed...
What you need to know about VSD’s
On February 22, 2023 the United States Department of Justice (DOJ) announced a policy, effective immediately, to provide a nationwide standard for how the U.S. Attorney’s Office (USAO) is to incentivize voluntary self-disclosures (VSDs) in DOJ enforcement matters. VSDs form an important part of the compliance-and- ethics (C&E) landscape and so C&E practitioners need to be aware of this development.
What is one of the biggest threats to company ethics?
Retaliation Retaliation happens more than we want to believe. Companies should treat it as a serious threat and manage it actively, as they would with other...
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...
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,...
Revisions to DOJ Program
On June 1, 2020, the U.S. Department of Justice (“DOJ”), Criminal Division, updated its guidance on the “Evaluation of Corporate Compliance Programs” (“the...
The New Antitrust Compliance Program Evaluation Criteria
For more than a quarter of a century the Antitrust Division of the US Justice Department (the “DOJ”) was an outlier among the components of the DOJ with...
Conducting Program Assessments Using the Department of Justice’s New Evaluation Standards
The modern era of corporate compliance began on November 1, 1991, when the Federal Sentencing Guidelines for Organizations (the “FSGO”) – the first set of...
Using behavioral ethics in compliance program assessments
Behavioral economics is a school of social science that teaches that we are not as rational as we think. The application of that learning to the realm of...
Culture assessment – the why and the how
Research conducted over the past twenty years has provided an evidentiary basis for what has – for just as long – been accepted wisdom in the E&C community:...
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...