Shon Ramey, general counsel of NAVEX Global, has a nifty suggestion: Have your compliance leaders and legal teams use the DOJ’s recently updated guidance for federal prosecutors, “Evaluation of Corporate Compliance Programs,” to evaluate your own compliance programs. “The main purpose of this updated guidance is to assist prosecutors as they investigate corporate compliance programs after an incident has occurred,” Ramey writes. “But it can also help us, as legal and compliance pros, to address any faults and weaknesses within our business processes. I’ve never met anyone that said, ‘My compliance program is perfect,’ so let’s use this document to be the best we can. Read more at Bloomberg Law.
Published November 23, 2020.
