Client Alert: DOJ Updates the Evaluation of Corporate Compliance Programs
This week the Department of Justice (DOJ) released their 2020 updates to the Evaluation of Corporate Compliance Programs, which was originally released in 2017. For many compliance professionals, this guidance represents the standard blueprint when building and enhancing an effective corporate compliance program.
Exiger has identified a few important 2020 highlights:
- Embrace Data: It should be no surprise the DOJ continues to place emphasis on leveraging data. In this latest version, they identify “operational data” to support risk assessments and updates but also outline data analytics as an important component for corporate helplines and third-party management. How compliance professionals’ access, analyze and manage data will only become more critical as data collection volumes increase across business units.
- Third-Party Endurance: As your company grows so does your third-party risk. DOJ emphasized their expectation that organizations manage and monitor third-parties throughout the entire life of the relationship. Due diligence, workflow, and monitoring are all important hallmarks of an effective risk-based third-party management system. Find out how
- Resources Matter: In the 2020 update, the DOJ outlines the important correlation between compliance resources and empowerment of the program. Compliance programs that are not adequately resourced quickly become ineffective. How organizations budget and support their compliance programs is an area DOJ will certainly review when assessing an organization’s level of commitment.