“This is interesting, but what am I supposed to do with, like, a million questions?”
– you, after reading the DOJ’s Evaluation of Corporate Compliance Programs.
Don’t worry. You’re not alone.
In fact, if that’s what you’re thinking: take heart. At least you’re in the 50% that has actually attempted to read it.
And to be clear, this is the document that the DOJ put out to explain how they tend to evaluate compliance programs. So it’s fair to say you should read it and figure out how to implement it—before you’re sitting across from a prosecutor.
The “implementation” part, however, is admittedly tough. [Read more…]