The Checklist That’s Not A Checklist Part 3: What does the new guidance from the 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 treads so that your program stays effective. Brought to you by Moorhead Compliance Consulting. Here's your host Eric Moorhead. Hi and welcome to the third part of a three part special edition of the podcast where we're talking about the evaluation of corporate compliance programs document that came out of the fraud section at the US Department of Justice just a few weeks ago. We've been talking, walking through the different parts of the document and I'm gonna continue on today and finish finally gonna finish today talking about the last few sections. If you haven't already subscribed to Compliance Beat please do that on our website or on iTunes. Please give us a review, if you have the time to do so, we sure appreciate it. And also check us out at moreheadconsulting.com. We have some other additional resources there that you might wanna check out. The next part, incentives and disciplinary measures, looks into an area that I think, as also kind of commonly, I wouldn't say overlooked, but less well developed. The first section, which talks about accountability and discipline, and how a company resolves and responds to misconduct. It relates to the things we were just talking about. Were managers held accountable, is a question. Did the company's response and consider...