ST0185DOJDOJ

ST0185

Prosecutors may reward efforts to promote improvement and sustainability. In evaluating whether a particular compliance program works in practice, prosecutors should consider “revisions to corporate compliance programs in light of lessons learned.” JM 9-28.800; see also JM 9-47-120(2)(c) (looking…

Assess my company

Plain-language summary

What it actually means.

Plain-language summary forthcoming. Source text below.

Source text

As written.

Prosecutors may reward efforts to promote improvement and sustainability. In evaluating whether a particular compliance program works in practice, prosecutors should consider “revisions to corporate compliance programs in light of lessons learned.” JM 9-28.800; see also JM 9-47-120(2)(c) (looking to “[t]he auditing of the compliance program to assure its effectiveness”). Prosecutors should likewise look to whether a company has taken “reasonable steps” to “ensure that the organization’s compliance and ethics program is followed, including monitoring and auditing to detect criminal conduct,” and “evaluate periodically the effectiveness of the organization’s” program.

Assessed by HEXDI

What HEXDI assesses.

M1
7 — MANAGEMENT COMMITMENT
Senior Management reviews audit reports and recommendations and regularly evaluates effectiveness of the program.
M2
5 — PROGRAM SETUP AND ADMINISTRATION
The Export/Import Compliance Council (or equivalent) regularly meets with the employee responsible for coordinating the program to review…
M2
1 — PROGRAM SETUP AND ADMINISTRATION
Program is developed using a reasoned methodology that is based on a thorough analysis and identification of risks pertaining to company…
M2
5 — PROGRAM SETUP AND ADMINISTRATION
Risk analysis and identification considers customer base, countries of exports/import activities, and product lines.
M2
7 — PROGRAM SETUP AND ADMINISTRATION
Risk analysis and identification considers findings from audits, evaluations, and other assessments and history of compliance problems.
M2
4 — PROGRAM SETUP AND ADMINISTRATION
Program provides a mechanism for employees to provide feedback on effectiveness of the program and to recommend improvements to increase…

Other DOJ standards.

Source & revisions

First mapped: Jun 8, 2022
Last updated: May 26, 2026 (13m ago)
Source: Evaluation of Corporate Compliance Programs