Ethics and compliance officers, internal auditors, and the like have tried to conduct periodic reviews of their programs, but that has taken on new importance thanks to and updated definition of “effective” compliance programs under the U.S. Sentencing Guidelines.
Those guidelines—whose most recent amendments went into effect Nov. 1—emphasize the importance of assessing compliance and ethics programs following the detection of criminal conduct. Periodic assessment can be critical to ensuring the success of your internal compliance and ethics program and can confirm that it is structured properly to deter and detect actual or potential violations or ...