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:
- Remedying Misconduct
- Involvement of Senior and Middle Management in the Program Compliance Autonomy and Resources
- Policies and Procedures
- Risk Assessment
Next week, in part two of this special edition, Eric will discuss the remaining topics:
- Training and Communication
- Confidential Reporting and Investigations
- Incentives and Disciplinary Measures
- Continuous Improvement, Periodic Testing and Review
- Third Party Management
- Mergers and Acquisitions
If you have a question you want answered on the podcast be sure to reach out below.