The Checklist That’s Not A Checklist Part 1: What does the new guidance from the DOJ Fraud Section mean?

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The Department of Justice Fraud Division released the Evaluation of Corporate Compliance Programs in middle of February without any announcement or fanfare. Is it a checklist? It looks like a checklist, but DOJ says it’s not a checklist or formula. Some of the information in the Evaluation you’ve heard before, but the “checklist” expands on it. If it’s not a checklist, what does it all mean? How can it help you?

In this first of a two part series, Eric discusses in depth five of the eleven topics covered in the Evaluation as well as their subtopics.  In this edition, Eric talks about:

  1. Remedying Misconduct
  2. Involvement of Senior and Middle Management in the Program Compliance Autonomy and Resources
  3. Policies and Procedures
  4. Risk Assessment

Next week, in part two of this special edition, Eric will discuss the remaining topics:

  1. Training and Communication
  2. Confidential Reporting and Investigations
  3. Incentives and Disciplinary Measures
  4. Continuous Improvement, Periodic Testing and Review
  5. Third Party Management
  6. Mergers and Acquisitions

 

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