The continued evolution of best practices for compliance programs

Assistant Attorney General Brian Benczkowski announced in April 2019 (ECI speech) an update to the 2017 Evaluation of Corporate Compliance Programs. This document is entitled Evaluation of Corporate Compliance Programs - Guidance Document (2019 ABC Guidance). It should be mandatory reading for every Chief Compliance Officer (CCO), compliance practitioner and professional or any other person interested in the latest guidance from the Department of Justice (DOJ) on what constitutes a best practices compliance program.

This Baker Tilly whitepaper discusses the 2019 ABC Guidance, identifies differences and newly listed items from the 2017 Evaluation of Corporate Compliance Programs and provides insight on how the document should be used. Compliance professionals who find themselves embroiled in a major compliance failure such as an investigation of a suspected violation of the Foreign Corruption Practices Act (FCPA) will find our whitepaper especially valuable. It will also help the compliance practitioner use the document as a road map to develop and implement a best practices compliance program.