ST1164DOJDOJ

ST1164

One hallmark of an effective compliance program is its capacity to improve and evolve. The actual implementation of controls in practice will necessarily reveal areas of risk and potential adjustment. A company’s business changes over time, as do the environments in which it operates, the nature of…

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Source text

As written.

One hallmark of an effective compliance program is its capacity to improve and evolve. The actual implementation of controls in practice will necessarily reveal areas of risk and potential adjustment. A company’s business changes over time, as do the environments in which it operates, the nature of its customers, the laws that govern its actions, and the applicable industry standards. Accordingly, prosecutors should consider whether the company has engaged in meaningful efforts to review its compliance program and ensure that it is not stale. Some companies survey employees to gauge the compliance culture and evaluate the strength of controls, and/or conduct periodic audits to ensure that controls are functioning well, though the nature and frequency of evaluations may depend on the company’s size and complexity.

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.

M2
2 — PROGRAM SETUP AND ADMINISTRATION
Methodology includes monitoring, collecting, and reporting of information on the number of exports/imports, nature and number of…
M2
4 — PROGRAM SETUP AND ADMINISTRATION
Risk analysis and identification occurs at Senior Management meetings as part of short- and long-term forecasting and strategic planning.
M2
7 — PROGRAM SETUP AND ADMINISTRATION
Risk analysis and identification considers findings from audits, evaluations, and other assessments and history of compliance problems.
M2
8 — PROGRAM SETUP AND ADMINISTRATION
Risk analysis and identification considers risks posed by new legislation, regulations, agency opinions and rulings, and court decisions.  
M2
9 — PROGRAM SETUP AND ADMINISTRATION
Risk analysis and identification considers risks posed by business, political, or economic changes.  
M2
10 — PROGRAM SETUP AND ADMINISTRATION
Risk analysis and identification considers risks posed by internal factors such as changes to product lines, staffing, operating processes,…

Other DOJ standards.

Source & revisions

First mapped: Jun 8, 2022
Last updated: Oct 28, 2026 (6d ago)
Source: DoJ Evaluation of Corporate Compliance Programs