Can Your Compliance Program Pass the Test?

Partners Doug Raymond and Dan Collins synopsized the Department of Justice’s (DOJ) revised guidance on corporate compliance program evaluation in a Directors & Boards article titled “Can Your Compliance Program Pass the Test?” Previously, the DOJ hinged evaluations on three core questions, taking into account whether programs were well-designed, actively operating and effective. In line with the DOJ’s long-documented criticisms of “paper programs,” the updated guidance emphasizes the importance of ongoing, demonstrable investment in corporate compliance programs, including, at a high level, “further training and development of compliance and control personnel.” Read on for the key agency considerations at the heart of the new guidelines.