ST1165DOJDOJ

ST1165

In evaluating whether a particular compliance program works in practice, prosecutors should consider “revisions to corporate compliance programs in light of lessons learned.” JM 9-28.800; see also JM 9-47-120(2)(c) (looking to “[t]he auditing of the compliance program to assure its effectiveness”).…

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Plain-language summary

What it actually means.

Plain-language summary forthcoming. Source text below.

Source text

As written.

In evaluating whether a particular compliance program works in practice, prosecutors should consider “revisions to corporate compliance programs in light of lessons learned.” JM 9-28.800; see also JM 9-47-120(2)(c) (looking to “[t]he auditing of the compliance program to assure its effectiveness”). Prosecutors should likewise look to whether a company has taken “reasonable steps” to “ensure that the organization’s compliance and ethics program is followed, including monitoring and auditing to detect criminal conduct,” and “evaluate periodically the effectiveness of the organization’s” program. U.S.S.G. § 8B2.1(b)(5). Proactive efforts like these may not only be rewarded in connection with the form of any resolution or prosecution (such as through remediation credit or a lower applicable fine range under the Sentencing Guidelines), but more importantly, may avert problems down the line.

Assessed by HEXDI

What HEXDI assesses.

M11
1 — AUDITS AND ASSESSMENTS
Program requires both internal and external audits to confirm whether procedures are performed as written and to determine effectiveness of…
M11
4 — AUDITS AND ASSESSMENTS
Program requires regular ongoing feedback, testing, and/or quality control assessments of processes on a regular basis outside of the audit…
M11
1 — AUDITS AND ASSESSMENTS
Audit guide requires comparison of audit results to prior audit results to identify any repeated deficiencies.
M11
2 — AUDITS AND ASSESSMENTS
Audit guide requires verification that prior audit corrective actions/recommendations were completed.
M11
2 — AUDITS AND ASSESSMENTS
Audit guide requires a written report on program deficiencies, areas for improvement, and recommended corrective actions identified in the…
M11
1 — AUDITS AND ASSESSMENTS
Program has procedures for investigating the underlying root causes giving rise to program deficiencies and other internal control problems…

Other DOJ standards.

Source & revisions

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