ST1166DOJDOJ

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.

to be determined

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.

Source & revisions

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