ST0977
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…
Plain-language summary
What it actually means.
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;
Assessed by HEXDI
What HEXDI assesses.
- 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.
- M12
3 — HANDLING VIOLATIONS
SAR system has an anonymous mechanism for employees to report suspected violations.
- M12
4 — HANDLING VIOLATIONS
SAR system immediately notifies management of employee reports of suspected violations.
Related
Other DOJ standards.
- DOJ41 citations
ST1166
DoJ Evaluation of Corporate Compliance Programs
- DOJ25 citations
ST1160
DoJ Evaluation of Corporate Compliance Programs
- DOJ24 citations
ST1154
DoJ Evaluation of Corporate Compliance Programs
- DOJ22 citations
ST0028
Evaluation of Corporate Compliance Programs
- DOJ22 citations
ST0535
Evaluation of Corporate Compliance Programs
Source & revisions
- First mapped
- Jun 8, 2022
- Last updated
- May 26, 2026 (15m ago)
- Source
- U.S. Attorneys' Manual