What is Monitoring and Auditing in an Effective Compliance and Ethics Program?

This week Eric talks about one of the hallmarks of the Sentencing Guidelines that is sometimes overlooked or not as carefully understood. Monitoring and auditing is sometimes reduced to reporting, but it is so much more. To guide us on the journey, Eric reviews the language and notes in the Sentencing Guidelines themselves and discusses the Department of Justice’s most recent guidance on the topic. Eric refers to both Chapter 8 of the Guidelines, which you can find here, and the February 2017 memo from DOJ, “Evaluation of Corporate Compliance Programs,” which you can find here.