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Stressing the Importance of Policies & Procedures

Apr 20 2017 | posted by Jeff Rosenbaum and Tara McCarthy | categories: Compliance Program Assessment

Earlier this year the Justice Department published its latest guidance yet about corporate compliance programs: a document titled “Evaluation of Corporate Compliance Programs,” that listed more than 100 questions the department might ask if it is investigating misconduct at your company. The guidance is specific, detailed, and comprehensive. The questions are written from the perspective of a prosecutor asking about a compliance program after a failure; but from them compliance officers can also reverse-engineer how a strong program should operate before a failure. The single longest section of the guidance dwells on policies and procedures. Those


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