2017 was a very significant year for every compliance practitioner and compliance program. The year brought two important documents on compliance programs. It began with the Evaluation of Corporate Compliance Programs (Evaluation) released in February 2017 and ended with the Department of Justice (DOJ) announcing a new Policy regarding Foreign Corrupt Practices Act (FCPA) enforcement in November 2017. Building upon the Ten Hallmarks of an Effective Compliance Program, as first articulated in the 2012 FCPA Guidance, there are now specific points, issues and questions a compliance professional can use to more fully operationalize your compliance program.

In November 2017, Deputy Attorney General Rod Rosenstein announced the new FCPA Corporate Enforcement Policy. This new Policy incorporated the Ten Hallmarks of an Effective Compliance Program through reference to the 2012 FCPA Resource Guide as continued best practices and added new information on the DOJ’s expectations for more fully operationalizing compliance. The DOJ further incorporated language and concepts from a variety of sources, including the 2016 FCPA Pilot Program and the 2017 Evaluation.

The Evaluation and Policy have laid out what compliance practitioners need to put into their compliance programs. Over the next 31 days, I will be exploring the best way to more fully operationalize a compliance program using the DOJ resources. Join me as we engage in 31 days to a more effective compliance program.

Three Key Takeaways

  1. 2017 brought two key DOJ documents forward for use by the compliance practitioner, the Evaluation and new FCPA Corporate Enforcement Policy.
  2. You must work to more fully operationalize your compliance program.
  3. Always remember the three most important things in any compliance program are: Document Document Document


This month’s podcast sponsor is Convercent. Convercent provides your teams with a centralized platform and automated processes that connect your business goals with your ethics and values. The result? A highly strategic program that drives ethics and values to the center of your business. For more information go to Convercent.com.