The original guidelines for prosecutors investigating Compliance issues defined 3 main topics:
- is the compliance program well-designed
- is the program effectively implemented
- does it actually work in practice?
Similar guidelines are follow by the FATF methodology which included technical compliance and factors of analysis of effectiveness.
As part of the rules of analysis, prosecutors should focus on governance, training, awareness and risk management in order to make sure that the appropriate compliance culture exists and is enforced.
As new point, the guidelines ask prosecutors to verify if the company reins up-to-date with newly created rules and regulations and if the compliance program implements and adapts to the appropriate framework.