The cornerstone of a best practices compliance program is its written standards. These include a Code of Conduct, policies and procedures. These requirements have long been memorialized in the US Federal Sentencing Guidelines (FSG), 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 Deferred Prosecution Agreement and See more +
The cornerstone of a best practices compliance program is its written standards. These include a Code of Conduct, policies and procedures. These requirements have long been memorialized in the US Federal Sentencing Guidelines (FSG), 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 Deferred Prosecution Agreement and Non-Prosecution Agreement. These requirements were incorporated into the 2012 FCPA Guidance. The FSG assumes that every effective compliance and ethics program begins with a written standard of conduct; i.e. a Code of Conduct. What should be in this “written standard of conduct? See less -
