10 Critical Lessons from the Changes to the US Department of Justice Guidance
On 1 June 2020, the US Department of Justice updated its guidance document “Evaluation of Corporate Compliance Programs” to reflect, as Assistant Attorney General Brian Benczkowki said, “additions based on our own experience and important feedback from the business and compliance communities.”
Over 130 participants from IIA Singapore and ACIIA Affiliates attended the webinar “10 Critical Lessons from the Changes to the US Department of Justice's Guidance” on 26 August 2021. The speaker, Kristy Grant-Hart, CEO of Spark Compliance Consulting shared the critical lessons found in this new guidance and how auditors can leverage this new information so they can evaluate and enhance their compliance programme, as well as effectively benchmark their programme against the US Department of Justice’s expectations.
Some of the key takeaways gathered from the session:
- There is an even higher bar for reviewing the programme’s effectiveness.
- Data and availability of data will strongly affect the prosecutor’s opinion of the programme.
- Contemporaneous notetaking about thought process and decision-making are critical.
