The DOJ updates its Guidance for the Evaluation of Corporate Compliance Programs
January 27, 2021
It’s time to think beyond just vendor due diligence and into vendor transaction monitoring
Effective June 2020, the U.S. Department of Justice (“DOJ”) updated its guidance for the Evaluation of Corporate Compliance Programs, enhancing its own guidance documents based on what its prosecutors have learned from investigations, compliance presentations, and monitorships during the past year.
Is your compliance program data-driven as expected in the DOJ’s new guidance?
- Does your company engage in risk management of third parties throughout the lifespan of the relationship, or primarily during the onboarding process?
- Do compliance and control personnel have sufficient direct or indirect access to relevant sources of data to allow for timely and effective monitoring and/or testing of policies, controls, and transactions?
- Do any impediments exist that limit access to relevant sources of data and, if so, what is the company doing to address the impediments?
- Is your periodic review limited to a “snapshot” in time or based upon continuous access to operational data and information across functions?
How will your company demonstrate a data-driven compliance program in-line with the updated best practices?
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