The Checklist That’s Not A Checklist Part 2: What does the new guidance from DOJ Fraud Section mean?

The Department of Justice Fraud Division released the Evaluation of Corporate Compliance Programs in middle of February without any announcement or fanfare. Is it a checklist? It looks like a checklist, but the DOJ says it’s not a checklist or formula. Some of the information in the Evaluation you’ve heard before, but the “checklist” expands on it. If it’s not a checklist, what does it all mean? How can it help you? Eric examines each of the Sample Topics and Questions that the DOJ puts forth in this new guidance. In this first of what has turned into a three part series, Eric discusses in depth five of the Sample Topics and Questions covered in the Evaluation.  In this edition, Eric talks about: Remedying Misconduct Involvement of Senior and Middle Management in the Program Compliance Autonomy and Resources Policies and Procedures Risk Assessment This week, in part two of this special edition, Eric delves into: Training and Communication Confidential Reporting and Investigations In part three, Eric will cover: Incentives and Disciplinary Measures Continuous Improvement, Periodic Testing and Review Third Party Management Mergers and Acquisitions   If you have a question you want answered on the podcast be sure to reach out below. https://twitter.com/eric_morehead LinkedIn -Eric Morehead https://www.facebook.com/compliancebeat/ Read Full Transcript Welcome to Compliance Beat, the podcast for compliance and ethics professionals. We provide practical insights and answer your questions about compliance and ethics. Together, we'll stay up to date on current trends so that your program stays effective. Brought to you by Moorhead Compliance Consulting. Here's your host, Eric Moorhead. Hello and welcome to the second part of what's now going to be a three part special edition of Compliance Beat podcast. We're talking about the checklist that's not a checklist that came from our friends at the fraud division within the division of the Department of Justice. The document known as the Evaluation of Corporate Compliance Programs came out just under a month ago. And we are walking through the different parts of the guidance that was provided within that document. If you haven't already, please listen to part one, where we talk about the first five. Sections. Also before we go too far, I've been remiss in the past in not saying this on the podcast, but if you haven't already, please, please go to compliancebeat.com or iTunes or wherever you happen to pick us up and subscribe. We really appreciate it. It means a lot to us and it also helps us Move the podcast forward. And secondly, if you have time, please visit us at moreheadconsulting.com where we have resources related both to this issue and many others for you to take a look at and we recently redesigned our website as well. So last week, we talked about the introduction and...