The DOJ announcement is timely because of the issue of risk events that are highly likely to have taken place with so many people working from home. It provides a guide to help organizations consider where such risk events will have occurred, and how best to mitigate them.
It also provides a framework to help organizations think about those core business processes that affect their compliance, and which rely on manual processes. The ‘new normal’ everyone is facing will rely on work-from-home strategies more than before the pandemic, even once we’ve emerged from it, and manual process that only work when everyone is in the office will need to be among the soonest to be removed.
The DOJ guidelines pose three questions: