A Compliance Self-Assessment

Thomas Fox
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Compliance Evangelist

In June, the Department of Justice (DOJ) published an Update to their Evaluation of Corporate Compliance Programs (2020 Update) which set out to provide additional clarity on how enforcement officials will evaluate an organization in the event of criminal misconduct. This enhanced guidance sets out a baseline, or the minimum standards to demonstrate an effective ethics and compliance program.

Now Convercent has updated their DOJ Interactive Self-Assessment, initially developed around the 2019 version of the Evaluation. (Full Disclosure – I assisted Convercent in this project and was compensated for my work). With the 2020 updates to the DOJ Guidance for Corporate Compliance Programs, it’s time again to do a health check on your own compliance program. How does it stack up? Are you still meeting the DOJ’s expectations?

Complete this interactive self-assessment to objectively rate how your program fares against the new guidelines. With over 200 questions and a brand-new section on data resources and access, this evaluation gives you a complete view of your compliance program, covering risk assessments, policies, training, reporting, third parties, and much more. Upon completing the assessment, you’ll get a scorecard mapping exactly where you can improve.

How It Works

The assessment sets out to dig into three fundamental questions:

  • Is your corporation’s compliance program well designed?
  • Is your corporate compliance program adequately resourced and empowered to function effectively?
  • Does your corporate compliance program work in practice?

The self-assessment then breakdowns questions for each of the categories listed in the 2020 Update, giving you the opportunity to assess where you are in each element. After compiling your answers, the document will provide a scorecard on the various sections and overall ratings of each high-level focus area. There are multiple and varied reasons for using the interactive self-assessment. Obviously, it gives you ways to see where your program is based upon the latest DOJ pronouncements as to what should go into a best practices compliance program.

One of the key themes from the 2020 Update was the compliance function’s use of data and information to continually monitor and continually. But it is beyond simply the access to data by the Chief Compliance Officer (CCO); it is the use of data. That is why this self-assessment is so useful and, more importantly, so critical. The self-assessment provides you with a detailed view of where you are able to make improvements to your company’s compliance initiatives. Continuous improvement is pivotal to ensuring success in ethics, and a consistent, honest evaluation of the program is the first step in the process. Equally important, it documents where you currently are so that you can begin to remediate any gaps you might find.

As ethics and compliance program maturity varies, so can the use of this tool. Whether building a new program, or continuing to evolve an advanced one, use the guidance as a framework for a self-assessment to determine gaps and opportunities within your ethics and compliance program. You can check out the Convercent Interactive Self-Assessment by clicking here.

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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.

© Thomas Fox, Compliance Evangelist | Attorney Advertising

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