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Program Component
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DOJ Evaluation Question
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Program Action Step
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Risk Assessment
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Section 1 (A): Does your company have a process for tracking and incorporating lessons from your own issues or from other companies into your own risk assessment process?
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Your organization should have processes in place to measure your compliance program effectiveness and should have access to reporting tools that help your company detect problems and analyze trends.
Your organization should also have visibility into industry-level data to evaluate and benchmark your compliance program against your peers – allowing you to identify where your program is succeeding and where your program can be improved.
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Policies and Procedures
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Section I (B): Are your organization’s policies and procedures published in a searchable format for easy reference?
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Your policies and procedures management system should have extensive search capabilities, allowing users to search by title, keyword, full text, or reference number.
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Section I (B): Does your organization track access to various policies and procedures to understand what policies are attracting more attention from relevant employees?
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Your system needs to be able to track how many times a policy has been viewed, who has viewed it, what version was viewed, and who has attested to the policy. |
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Training and Communications
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Section 1 (C): What is the interactive nature of your training? Does it provide opportunities to ask questions?
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Your training courses should be interactive and provide learners with access to your organization’s policies, as well as information on how to ask questions or make a report. These interactive resources should always be available to learners throughout a training course.
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Section 1 (C): Can you accurately measure the impact of your training and how it affects employee behavior or operations?
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Your Learning Management System (LMS) should deploy, track and report on compliance training programs, including metrics that measure progress toward goals. Program administrators should also be able to validate course completions and overall program health through dashboards and audit-ready reporting. |
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Confidential Reporting Structure and Investigation Process
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Section 1 (D): Can your company confirm employee awareness of your hotline?
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As part of your organization’s hotline and investigation management system, you should have a selection of awareness materials including posters, brochures and wallet cards.
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Section 1 (D): Are you periodically testing the effectiveness of your hotline (e.g. by using a tracking report)?
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To accurately test and measure the effectiveness of your hotline, your organization should have access to reporting tools that help detect problems and analyze trends. Reporting should also include details about the status, volume and resolution of your investigations. |
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Third-Party Management
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Section 1 (E): Are your risk assessments of third parties done throughout the life span of the relationship, or just during the onboarding process?
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Your third-party risk management solution should allow you to not only screen, but continuously monitor third parties against adverse media, sanctions lists, politically exposed persons. It should also support real-time reputation alerts when a third party’s status changes and additional due diligence when needed.
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