Scott Moritz, Protiviti Managing Director, Protiviti Forensic
In February of 2017, the U.S. Department of Justice (DOJ) Fraud Section released the Evaluation of Corporate Compliance Programs guidance, which references the FCPA Resource Guide and the Hallmarks of Effective Compliance Programs. This publication introduced the term “conduct at the top” and also placed emphasis on subjects such as the importance of “operationalizing” compliance and holding individuals accountable. The government is asking businesses to embed compliance into business operations and to make sure compliance and ethics start at the top of the organization. Those who fail to operationalize compliance or turn a blind eye to illegality within their organizations will be held accountable.