In conjunction with the 5-part podcast series that Tom Fox hosted in January with Eric Feldman and Vin DiCianni on the DOJ announcements over the past year, Feldman joined Fox for a blog post to consider what strategies companies can use based upon these guidelines. The podcast series will explore how the Benczkowski Memo (the “Memo”) and other DOJ guidance into compliance programs can be used by compliance professionals to create more robust compliance programs. Feldman believes the Memo can be used as both a sword and shield in furtherance of more effective compliance programs.
Read part 1 HERE
In this second blog post, DiCianni emphasizes that the DOJ now mandates companies which come before them have an effective compliance program. Companies must demonstrate they had an effective compliance program, not a paper compliance program.