Responding to Detected Offenses and Developing Corrective Action Initiatives: Element 7
One of the most important aspects of an effective compliance program is making corrections to the systems or processes of the organization when something does go bump in the night. The Department of Justice, in its March 2023 Evaluation of Corporate Compliance Programs document specifically addresses this essential element. As stated by the DOJ “One […]
The Hits Just Keep Coming!
On November 6, 2020 the Office for Civil Rights issued a press release announcing the settlement of its Tenth investigation under the Right to Access Initiative. I have written about this initiative before in this blog but in light of the fact it seems like there is a new press release on the subject every […]
Dynamic and Evolving
In June 2019, when the Criminal Division of the Department of Justice, (DOJ), updated its guidance document on how prosecutors are to evaluate an organization’s compliance program, (Evaluation of Corporate Compliance Programs), one theme comes through loud and clear. Compliance policies, procedures and controls should never become stale or stagnant. Rather, the DOJ takes the […]