ST0967DOJDOJ

ST0967

In evaluating compliance programs, prosecutors may consider whether the corporation has established corporate governance mechanisms that can effectively detect and prevent misconduct. For example, do the corporation's directors exercise independent review over proposed corporate actions rather than…

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Plain-language summary

What it actually means.

to be determined

Plain-language summary forthcoming. Source text below.

Source text

As written.

In evaluating compliance programs, prosecutors may consider whether the corporation has established corporate governance mechanisms that can effectively detect and prevent misconduct. For example, do the corporation's directors exercise independent review over proposed corporate actions rather than unquestioningly ratifying officers' recommendations; are the directors provided with information sufficient to enable the exercise of independent judgment, are internal audit functions conducted at a level sufficient to ensure their independence and accuracy and have the directors established an information and reporting system in the organization reasonably designed to provide management and the board of directors with timely and accurate information sufficient to allow them to reach an informed decision regarding the organization's compliance with the law.

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.

  • M12

    1 — HANDLING VIOLATIONS

    Program includes a Suspicious Activity Reporting (SAR) system for collecting, analyzing, and using information on suspected violations.

  • M12

    2 — HANDLING VIOLATIONS

    SAR system has a 24-hour mechanism for employees to report suspected violations.

Related

Other DOJ standards.

Source & revisions

First mapped
Jun 8, 2022
Last updated
May 26, 2026 (14m ago)
Source
Principles of Federal Prosecution of Business Organizations