Evaluating DOJ compliance guidance in 2020 | Deloitte US
About the DOJ compliance guidance updates. On June 1, 2020, the DOJ updated its guidance document entitled Evaluation of Corporate Compliance Programs (ECCP). 1 Subsequently, on July 3, 2020, the DOJ and US Securities and Exchange Commission (SEC) issued an updated version of their 2012 “A Resource Guide to the U.S. Foreign Corrupt Practices Act.” 2 As DOJ and SEC’s expectations continue ...
compliance program? While there are a number of factors that separate the “good” from the “great,” in our experience, there are five factors that are key differentiators in the highest-performing ethics and compliance programs. Tone at the top—The starting point for any world-class ethics and compliance program is the board and senior
2020年7月30日 · On June 1, 2020, the DOJ updated its guidance document entitled Evaluation of Corporate Compliance Programs (ECCP).1 Subsequently, on July 3, 2020, the DOJ and SEC issued an updated version of their 2012 “A Resource Guide to the U.S. Foreign Corrupt Practices Act” (“ResourceGuide”).2 As DOJ and
Good To Great Ethics and Compliance | Deloitte US
While there are a number of factors—or ingredients—that separate the “good” from the “great,” in our experience, there are five that are key differentiators in the highest performing compliance programs: Tone at the top; Corporate culture; Risk assessments; The chief compliance officer; Testing and monitoring
the best compliance programs. It is the role of compliance to prepare companies to be thoughtful and proactive to determine where such issues may arise and to respond to remediation efforts swiftly, appropriately, and ensure that same issue does not occur again. existing one." 1 United States Federal Sentencing Guidelines 9-28.300
Building world-class ethics and compliance programs
The ethics and compliance function and how it has evolved over the past decade. It is now front and center with greatly expanded responsibilities. When it comes to creating ethics and compliance programs, organizations today cannot afford to settle for “good enough” and should continuously strive for “great.”
Enterprise Compliance Risk Management Services | Deloitte US
Enterprise compliance is a centralized, coordinated approach to ethics and compliance program design and assessment that cuts across multiple business units within an organization. A programmatic approach, built from the top down, enterprise compliance risk management focuses on the specific risks the organization faces.
evaluating a corporate compliance program: (1) is the program well designed, (2) is the program being implemented effectively, and (3) does the program work in practice? Prosecutors may consider the comprehensiveness of the program (e.g., risk assessment, policies and procedures, training programs,
Evaluating DOJ compliance guidance in 2019 - Deloitte United States
2019年7月19日 · The new guidance makes it clear that going beyond self-assessment of a company’s compliance program to undergo regular outside evaluations of program effectiveness may be viewed favorably by prosecutors. As the DOJ makes clear, compliance programs must be well-designed, effective, and work in practice.
Five insights into anti-corruption compliance programs
Corporate compliance teams can benefit from remaining highly vigilant and considering the following insights as they review and refresh their anti-corruption compliance programs. In this article, Deloitte outlines the ways companies should take a fresh look at their anti-corruption compliance programs in light of ongoing enforcement of the ...