Blog: effective compliance

 

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DOJ’s Monaco Memorandum Refocuses on Individual Accountability, Prompt Self-Disclosure, and Clear Guidelines to Prosecutors

Posted on September 21, 2022 by
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In September 2022, the United States Department of Justice (DOJ) released a memorandum from Deputy Attorney General Lisa Monaco that included significant changes to the way the DOJ handles corporate criminal enforcement.  The (Monaco Memorandum) built upon and expanded the DOJ’s manner of handling so-called “white collar” crimes and provides guidelines for federal prosecutors across […]

The Essence of Compliance – Compliance Officer Authority and Resource Allocation

Posted on May 24, 2019 by
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How Are Compliance Budgeting and Compliance Officer Autonomy Tied Together When Assessing Compliance Effectiveness? The Department of Justice (“DOJ”)’s compliance program evaluation identifies the need to allocate sufficient revenues to the compliance program as one of the key issues that indicates compliance program effectiveness.  The issue of resource allocation has been identified since the early […]

Best Practices in Compliance Program Operation

Posted on April 4, 2017 by
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Given the increased importance of compliance, it is helpful for providers to get a feel for what constitutes “best practice” when operating a compliance program.  “Best Practices” is a term thrown around all of the time in the business world.  It is used in many contexts and takes on a variety of meanings depending on […]

Setting Up Your Compliance Internal Reporting Mechanism

Posted on March 3, 2017 by
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Department of Justice Issues Principles of an Effective Compliance Program

Posted on February 23, 2017 by
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The Department of Justice issued a directive entitled “Evaluation of Corporate Compliance Programs.”  The document provides insight into the analysis used by the DOJ to assess the effectiveness of a corporate compliance program when making sentencing recommendations under the United States Sentencing Guidelines. The document references the Principles of Federal Prosecution of Business Organizations included […]