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On the evaluation of corporate compliance programs

Tom Fox | February 21, 2017

Very quietly, on February 8th, the Justice Department released a document, entitled “Evaluation of Corporate Compliance Programs” (Evaluation), on its Fraud Section website. It was not detected by the compliance community until last week. The document is an 11-part list of questions that encapsulates the Justice Department’s most current thinking on what constitutes a best practices compliance program. Within the list are 46 different questions that a Chief Compliance Officer or compliance practitioner can use to benchmark a compliance program. Even with this no-publicity release, it is an incredibly valuable and most significantly useful resource for every compliance practitioner.

The Evaluation, most generally, follows the Justice Department and SEC’s seminal “Ten Hallmarks of an Effective Compliance Program,” released in the 2012 FCPA Guidance. If there is one overriding theme in the...

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