ST0966DOJDOJ

ST0966

While the Department recognizes that no compliance program can ever prevent all criminal activity by a corporation's employees, the critical factors in evaluating any program are whether the program is adequately designed for maximum effectiveness in preventing and detecting wrongdoing by employees…

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Source text

As written.

While the Department recognizes that no compliance program can ever prevent all criminal activity by a corporation's employees, the critical factors in evaluating any program are whether the program is adequately designed for maximum effectiveness in preventing and detecting wrongdoing by employees and whether corporate management is enforcing the program or is tacitly encouraging or pressuring employees to engage in misconduct to achieve business objectives.

Change history

When and why it changed.

Present in the original catalog

This standard has not changed since it was added.

Assessed by HEXDI

What HEXDI assesses.

M1
4 — MANAGEMENT COMMITMENT
Senior Management maintains sufficient oversight over development and implementation of the program.
M1
5 — MANAGEMENT COMMITMENT
Senior Management maintains sufficient oversight over maintenance of the program.
M1
6 — MANAGEMENT COMMITMENT
Senior Management maintains sufficient oversight over employee adherence to the program.
M1
7 — MANAGEMENT COMMITMENT
Senior Management reviews audit reports and recommendations and regularly evaluates effectiveness of the program.
M1
8 — MANAGEMENT COMMITMENT
A specific member of Senior Management is assigned with overall responsibility for the program.
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…

Other DOJ standards.

Source & revisions

First mapped: Jun 8, 2022
Last updated: Oct 28, 2026 (5d ago)
Source: Principles of Federal Prosecution of Business Organizations