The US Attorney’s Manual was just updated prior to the holidays, an early present for organizations, and the new guidance codifies what was known as the “FCPA Pilot Program” and provides us a lot of helpful information about compliance expectations from the Department of Justice.
Eric spends a few minutes going through the new chapter in the US Attorney’s Manual and talks about how compliance officers can use this information to both evaluate their programs and responses to the risks, as well as use it as additional backup when discussing needs and requirements with stakeholders.
There is a lot here about independence, resources and access for the compliance office, as well as zeroing in on risk and root cause analysis. Specific inquiries we started to see in the last few years that are now in black and white. So organizations should make sure they are addressing these standards — because the Department of Justice will be checking. While this is focused on the FCPA and anti-corruption and anti-bribery, the guidance is helpful generally when discussing the readiness of compliance and ethics programs.