Our summary
This Department of Justice guidance tells prosecutors how to evaluate a company’s compliance program when deciding how to resolve a case. It asks three core questions: is the program well designed, is it adequately resourced and empowered, and does it work in practice?
Although written for U.S. prosecutors, it is widely used around the world as a practical benchmark for any compliance program.
How auditors use it: as a ready-made checklist when auditing a compliance function, from risk assessment and training to speak-up channels and investigations.