US Department of Justice publishes guidelines for corporate compliance

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.



Jaime Prieto

Mr. Jaime Prieto is a lawyer experienced in Financial Crime, Anti-Money Laundering and Counter Terrorism Financing having extensive professional experience in both public and private sectors. Mr. Prieto has been a Head of Compliance in the European Union, the Americas and the Caribbean for banks, trust companies, asset managers, Big Four audit and advisory firms, RegTechs, government agencies and other types of financial professionals. In addition to his experience, he has been legal and educational chair in several compliance and sectorial organisations and performed as a teacher and speaker for a number of organisations and in several local and international forums. Furthermore, Mr. Prieto is an experienced Money Laundering Reporting Officer anda Data Protection officer with additional experience in risk management.
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