Meaningful Compliance – Defining your Compliance Program

Where does Compliance rank in your organization compared to other functions/priorities?

  • Does the Compliance Officer have the same clout as other executives?
  • Does Compliance play a role in your organization’s strategic and operational decisions?
  • What Compliance expertise is made available/provided to the Board?
  • What specific actions have senior leaders and other stakeholders taken to demonstrate commitment to compliance?

The above questions are just an excerpt of the nuanced questions outlined in the Department of Justice (DOJ) guidelines, Evaluation of Corporate Compliance Programs. Central to the guidelines issued by the DOJ is evidence of meaningful compliance – not just a plan on paper. Although these guidelines are questions that prosecutors would ask during fraud investigations, the detail is unprecedented and should be used by Compliance Officers in conjunction with longstanding Office of Inspector General guidance to evaluate compliance effectiveness.

How Should Your Compliance Department Utilize this Information?

  • Review the guidance and develop an Effectiveness Checklist using the relevant topics and questions
  • Conduct a Compliance Effectiveness Assessment using the Checklist
  • Identify Opportunities for Improvement
  • Implement effective tools and practices
  • Educate

The DOJ’s guidance should act as an alert to Compliance Officers to confirm the adequacy of their Program. Not sure where to start? Our team of compliance professionals have years of experience developing best practice compliance programs and regularly assessing their effectiveness. For more information, contact us at

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