ST1166
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”…
Plain-language summary
What it actually means.
Plain-language summary forthcoming. Source text below.
Source text
As written.
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).
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
2 — AUDITS AND ASSESSMENTS
Program requires unit/functional level audits.
- M11
3 — AUDITS AND ASSESSMENTS
Program requires program level audits.
- 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
The scope and frequency of audits are determined based on the company’s ongoing risk analysis and identification.
- M11
3 — AUDITS AND ASSESSMENTS
Program requires audits on at least an annual basis.
Related
Other DOJ standards.
- 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
- DOJ22 citations
ST1161
DoJ Evaluation of Corporate Compliance Programs
Source & revisions
- First mapped
- Jun 8, 2022
- Last updated
- May 26, 2026 (15m ago)
- Source
- DoJ Evaluation of Corporate Compliance Programs