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.
