ST1163DOJDOJ

ST1163

Another hallmark of effective implementation of a compliance program is the establishment of incentives for compliance and disincentives for non-compliance. Prosecutors should assess whether the company has clear disciplinary procedures in place, enforces them consistently across the organization,…

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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.

Another hallmark of effective implementation of a compliance program is the establishment of incentives for compliance and disincentives for non-compliance. Prosecutors should assess whether the company has clear disciplinary procedures in place, enforces them consistently across the organization, and ensures that the procedures are commensurate with the violations. Prosecutors should also assess the extent to which the company’s communications convey to its employees that unethical conduct will not be tolerated and will bring swift consequences, regardless of the position or title of the employee who engages in the conduct. See U.S.S.G. § 8B2.1(b)(5)(C) (“the organization’s compliance program shall be promoted and enforced consistently throughout the organization through (A) appropriate incentives to perform in accordance with the compliance and ethics program; and (B) appropriate disciplinary measures for engaging in criminal conduct and for failing to take reasonable steps to prevent or detect criminal conduct”).

Assessed by HEXDI

What HEXDI assesses.

  • M1

    1 — MANAGEMENT COMMITMENT

    Program includes a Policy Statement signed by a senior executive officer or equivalent that clearly communicates the organization’s…

  • M1

    2 — MANAGEMENT COMMITMENT

    Policies instruct that no transactions will be made contrary to export/import or other U.S. laws.

  • M1

    1 — MANAGEMENT COMMITMENT

    Policies clearly communicate the organization’s commitment to compliance with export/import laws and ethical conduct in international trade.

  • M1

    6 — MANAGEMENT COMMITMENT

    Senior Management maintains sufficient oversight over employee adherence to the program.

  • M10

    1 — RECORDKEEPING

    Policies emphasize the need to accurately report information in company records and reports to agencies and instruct that all dealings with…

  • M12

    1 — HANDLING VIOLATIONS

    Program has procedures for tracking and ensuring timely completion of corrective actions for violations.

Related

Other DOJ standards.

Source & revisions

First mapped
Jun 8, 2022
Last updated
May 26, 2026 (15m ago)
Source
DoJ Evaluation of Corporate Compliance Programs