The Updated Evaluation of Corporate Compliance Programs – Guidance Document: Part 2 – A Well Designed Program

May 3, 2019

We are in an exploration of the recently released Evaluation of Corporate Compliance Programs – Guidance Document (2019 Guidance), which was announced (ECI speech) by Assistant Attorney General Brian Benczkowski at the Ethics and Compliance Initiative (ECI) Impact 2019 Conference. It is an update to the 2017 Evaluation of Corporate Compliance Programs, released in February 2017. This new document is available for download at no charge. It should be mandatory reading for every Chief Compliance Officer (CCO), compliance practitioner and professional or any other person interested in the latest thinking of the Department of Justice (DOJ) on what constitutes a best practices compliance program. Today, I consider the first substantive section of the 2019 Guidance, what should go into a well-designed compliance program or as it states, “Is the corporation’s compliance program well designed?” – Tom Fox, Compliance Evangelist, FCPA Compliance Report

Read the full article written by Tom Fox on the FCPA Compliance Report website here.