Tagged: continuous improvement

Assessing Your Audit and Testing Program (Part IV of IV)

Assessing Your Audit and Testing Program (Part IV of IV)

Continuous improvement of a compliance program requires robust auditing and testing.  The Justice Department and regulatory agencies have articulated a number of key issues and principles to assist CCOs and Internal Auditors in this area.  It is likely to become an area for DOJ and regulatory agency focus — what steps does the company take to review its compliance program to ensure that it is...

Episode 241 — Continuous Improvement, Testing and Auditing of Your Ethics and Compliance Program

Episode 241 — Continuous Improvement, Testing and Auditing of Your Ethics and Compliance Program

The Justice Department and various regulatory agencies continue to emphasize the importance of continuous improvement, testing and review as part of robust assessment procedures in an effective compliance program.  The Treasury Department’s Office of Foreign Asset Control has specifically stated that a sanctions compliance program should include “a comprehensive, independent, and objective testing or audit function” so that a company can determine “how their program[]...