Register for a complimentary CEU credited webinar “Building Blocks for Effective Compliance Programs (sai360.com),” November 10, 2022, at 2 PM Eastern. The Compliance Certification Board (CCB)® has approved this event for up to 1.2 Live CCB CEUs.
The DOJ Compliance Program Effectiveness Evaluation Guidelines has many warnings of “red flags,” which they consider indicators of non-compliance. The following are examples of such indicators and organizations should take steps to ensure they don’t have them.
- A compliance program is not in place.
- A compliance plan exists, but it has not been fully implemented.
- The Board does not evidence familiarity with the compliance program operation.
- The Compliance Officer is unable to evidence having regular and direct access to the Board.
- The Board doesn’t meet with the Compliance Officer in executive sessions without management presence.
- The Compliance Officer is not a member of executive leadership, like the CFO, CIO, GC.
- There is no or poorly written Code of Conduct to provide employee guidance.
- There are inadequate policies and procedures for management/operation of the Compliance Program.
- Absences of an anonymous reporting channel for employees.
- Structured root-cause analyses of compliance-related incidents have not been performed.
- Absence of or weak compliance audit work plans.
- Regulatory compliance risk assessments have not been performed.
- Employees have not been surveyed regarding compliance.
- No recent independent compliance program evaluation has been performed.
- Meaningful incentives have not been offered to employees to encourage compliance.
- Evidence of inconsistent application of disciplinary actions.
- The Compliance Officer has not been involved in performing due diligence for potential acquisitions.
- The Compliance Officer is not involved in executive strategy meetings, discussions, or decisions.
- Evidence of inadequate resources for the compliance program.
- The Compliance Officer has not been empowered to make independent decisions.
- Evidence of inadequate authority to address compliance issues at all levels.
For related FAQs, see https://www.compliance.com/faqs/
Keep up-to-date with Strategic Management Services by following us on LinkedInSubscribe to blog