Tagged: discipline and incentives

DOJ Compliance Expectations Concerning Training, Internal Investigations and Audits (Part IV of IV)

DOJ’s Compliance Evaluation questions provide important indications of “new” trends and approaches to compliance functions and issues. Training In the area of training, DOJ’s Compliance Evaluation reiterates DOJ’s concern that companies tailor their training programs to their specific risk profile. In the FCPA Guidance issued in 2012, DOJ explained that training programs should be tailored to specific audiences. DOJ has refined this requirement to focus...