“Compliance starts at the top. Cultivating a culture of compliance requires senior leaders to commit to compliance and communicate the duty to report, sending a clear message that compliance matters. ”
— Laura Martin, Partner, Katten Muchin Rosenman LLP
Explore a list of helpful questions to evaluate the impact and effectiveness of your compliance program under Department of Justice (DOJ) guidelines. Listen to a thoughtful discussion and recommendations on the strategic side of compliance budgets, and learn how company leaders recognize and respect the regulatory role in business resilience.
From Paper to Practice: Questions to Evaluate the Real-World Impact of Your Compliance Program Under DOJ Guidelines
The DOJ issued guidance on the “Evaluation of Corporate Compliance Programs” to assist prosecutors in making informed decisions as to what extent a corporate compliance program was effective at the time of an offense and at the time of a charging decision or resolution. A compliance program that is effective in practice, not simply on paper, is crucial when the DOJ considers results. Here is a list of questions to evaluate the factors of effectiveness highlighted in the DOJ guidance and, if necessary, implement improvements to minimize institutional compliance risk.
The Strategic Side of Compliance Budgets
Betsey Wade, the Chief Compliance & Ethics Officer at Signature Healthcare, says a compliance budget is much more than the numbers—it should reflect the organization’s priorities and risk profile. The budget is also a focus point for the US Department of Justice when examining a compliance program during an investigation. Their guidance for prosecutors asks if there are sufficient resources and if they are allocated on a “risk-tailored” basis. So, what is the right budget to have? To determine that answer, Wade recommends compliance teams do a risk assessment and determine what mitigation efforts will be needed. In addition, benchmark against other organizations to learn what they are spending and doing. Listen to the full podcast to hear more from Wade about the strategic side of compliance budgets.
In Resilience Efforts, Companies Welcome Regulator Role
According to Deloitte’s 2022 Global Resilience Survey report, executives responsible for resilience recognize and respect regulators’ role in resilience. However, they also understand that the events that frequently occur and the potential threats they pose are too significant and widespread for any organization to address. Two-thirds (67%) of respondents say their organizations have been affected by regulatory involvement in resilience, while 31% have not. According to the report, in the context of resilience, organizations see regulation positively because it helps to clarify priorities by setting forth specific areas of focus, objective goals, and clear reporting requirements. Overall, over 90% of organizations affected by regulatory change report that the impact on resilience has been very or somewhat positive. Learn more about the report findings.