What is the DOJ Corporate Compliance Guidance?

The Evaluation of Corporate Compliance Programs is the U.S. Department of Justice’s guidance to federal prosecutors on how to determine the size and severity of punishment a company should face in the event of a compliance failure.

 

The Challenge of addressing DOJ Compliance Guidance

With the DOJ’s June 2020 update to their guidance on corporate compliance programs, regulators have further sought to provide guidance and transparency to organizations by clearly communicating their expectations of what a well-designed and properly executed compliance program should look like. 

 

Compliance officers can start by answering the three questions the DOJ instructs prosecutors to ask at the start of their evaluation:

1. Is the corporation’s compliance program well designed?
2. Is the program adequately resourced and empowered to function?
3. Does the program work in practice? 

 

The DOJ guidance then provides detailed questions to evaluate each response. Someone measuring a risk and compliance program’s design, for example, should start by reviewing its risk assessment. How did the company define its risk profile? Did it tailor its programs to detect the specific types of misconduct identified, and allocate resources accordingly? Did it periodically review and revise its assessment? By proactively addressing the questions posed in the DOJ guidance, organizations can prevent the need for prosecutors to seek answers in the wake of compliance failure.  

How does Diligent support customers trying to build credible defensible well designed and auditable compliance programs?  

Third-Party Risk Management
Systemize the onboarding and monitoring of third-parties using an intuitive workflow platform that automates compliance processes. 
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Due Diligence 
Gain access to reliable, effective due diligence intelligence to build a seamless, comprehensive and global due diligence program. 
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Risk Intelligence Data 
Access the most up-to-date data on key customers and vendors from millions of global sources.  
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Compliance & Ethics Training 
Build a stronger culture of compliance that meet regulatory standards. 
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Board and Leadership Collaboration
Improve secure board and leadership collaboration by conducting board, committee and leadership meetings with confidence.
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Integrated Risk Management 
Gain a complete view of your risk landscape and deliver assurance across your organization. 
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Additional DOJ Corporate Compliance Insights 

WHITEPAPER

Evaluation of Corporate Compliance Programs 2022 Supplement

Recent statements made by senior DOJ officials only underscore the importance of adhering to the Guidelines when making corporate compliance decisions. 
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Evaluation of Corporate Compliance Programs: 2022 Supplement

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The 5 Stages of Behavior Change Science and Compliance

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Diligent Master Class for CCOs

Diligent Master Class for CCOs is a one-of-a-kind program that provides actionable advice and frameworks for today’s compliance leaders.
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How To Avoid the Consequences of Noncompliance in Business

No matter the context, noncompliance with regulations or legislation generally has serious repercussions for businesses — reputational, financial, even criminal charges and prison time.
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