DOJ guidance on effective corporate compliance programs: What it could mean for you


In June 2020, the Department of Justice (DOJ) updated its guidance for evaluating compliance programs. The new guidance is centered on three fundamental questions, with specific updates to effectiveness:

  • Is the compliance program well designed? 
  • Is it adequately resourced and empowered to function effectively?
  • Does it work in practice?

And it also adopts a more practical approach that takes into account a company’s individual, real-world business circumstances. It’s especially relevant right now, as companies navigate the human, economic and operational fallout of a global pandemic—with constrained resources, overstretched compliance teams, and employees struggling to maintain continuity working from their homes.

Every day, we are talking to companies and leaders just like you to understand the updated guidance and what it means to your people, your programs, your technology - and to your brand and reputation.

The DOJ’s new guidance has raised the bar for compliance programs. What steps can you take now?

  • Focus on a risk-based approach - including steps to assess and identify higher risk areas of business, third parties and activities.
  • Engrain compliance within the fabric of your company - ensure it goes beyond a “paper program" and drives meaningful results.
  • Holistically address risk across the third party lifecycle.
  • Transform your data to work for you by leveraging automated tools that can enable more proactive measures and enhance visibility.
  • Adapt your program based on insights gained from industry benchmarking and internal evaluations.

Revised guidance issued by the DOJ aims to sharpen prosecutors’ understanding of what works — and what doesn’t — when evaluating a company’s compliance program design, effectiveness, and application. Interested in what this could mean for your company?

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Justin Offen

Justin Offen

Principal, PwC US

Ryan Murphy

Ryan Murphy

Partner, Global Investigations & Forensics Leader, PwC US

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