Hallmarks of an Effective Compliance Program- as articulated by Assistant Attorney General Leslie Caldwell

On November 2, 2015, Leslie Caldwell spoke before the SIFMA Compliance and Legal Society in New York and discussed the hiring of a Compliance Expert (Hui Chen) to assist DOJ in evaluating compliance programs.  Ms. Caldwell also took the time to outline the metrics that the new Compliance Counsel will use to assess a compliance program. These include:

1.  Does the institution ensure that its directors and senior managers provide strong, explicit and visible support for its corporate compliance policies?

2. Do the people responsible for compliance have stature within the company?

3. Are the company’s compliance policies clear and in writing and easily understood by employees?

4. Does the institution ensure that the policies are effectively communicated to all employees and in their native language?

5. Does the company review its policies and practices and keep them up to date with evolving risks?

6.  Are there mechanisms in place to enforce compliance policies?

7. Does the company require third party vendors to understand the company’s compliance expectations?

Ms. Caldwell’s entire remarks can be found here and is well worth the read.  www.justice.gov/opa/speech/assistant-general-leslie-r-caldwell-speaks-sifma-compliance-and-legal-society.