31 Days to a More Effective Compliance Program - Clearly articulated written standards

Thomas Fox
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The written standard requirements have long been memorialized in the U.S. Sentencing Guidelines, which contain seven basic compliance elements that can be tailored to fit the needs and financial realities of any given organization. From these seven compliance elements, the DOJ has crafted its minimum best practices compliance program, which is now attached to every DPA and NPA issued. These requirements were incorporated into the 2012 FCPA Guidance and brought forward in the 2019 Guidance and FCPA Corporate Enforcement Policy. The See more +
The written standard requirements have long been memorialized in the U.S. Sentencing Guidelines, which contain seven basic compliance elements that can be tailored to fit the needs and financial realities of any given organization. From these seven compliance elements, the DOJ has crafted its minimum best practices compliance program, which is now attached to every DPA and NPA issued. These requirements were incorporated into the 2012 FCPA Guidance and brought forward in the 2019 Guidance and FCPA Corporate Enforcement Policy. The U.S. Sentencing Guidelines assumes that every effective compliance and ethics program begins with a written standard of conduct; i.e., a Code of Conduct.

Three key takeaways:

1. A Code of Conduct, together with policies and procedures, have long been recognized as cornerstones of a best practices compliance policy.

2. Each level of written standards builds upon one another, so consider this integration step.

3. The Fair Process Doctrine applies to your written standards. See less -

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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