The Department of Justice in February quietly released a document, “Evaluation of Corporate Compliance Programs” (Evaluation), on the Fraud Section of its website. The document is an 11-part list of questions that encapsulates the DOJ’s most current thinking on what constitutes a best practices compliance program. Within the list are some 46 different questions that a Chief Compliance Officer (CCO) or compliance practitioner can use to benchmark a compliance program. In short, it is an incredibly valuable and most significantly useful resource for every compliance practitioner.
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