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Evaluating your program according to the DOJ's Filip Factors

Daniel Coney (danconey@comcast.net), based in Lakewood, Colorado, USA, has been a law enforcement professional for more than 35 years, with the last 29 years being both an agent and supervisor in four different Office of Inspector General organizations.

Compliance can be a difficult and thankless job—until you’re needed. Then the work you’ve been doing behind the scenes is crucial to the long-term sustainability of the company, the board, and leadership. Your diligence is particularly important when law enforcement comes calling—not just having an effective compliance program in place, but in demonstrating that it is worth the paper it is written on. With that in mind, I thought it would help the practitioner to see what advice I’ve given the agents who work for me in the value of understanding the intersection of investigative work and the discipline of corporate compliance.

This article introduces a tool (Table 1) derived from the source that the U.S. Department of Justice uses to evaluate company compliance plans, the Filip Factors. The tool identifies key factors that law enforcement will seek information about and particular questions they may be asking. Taken from the viewpoint of a compliance professional, however, the tool also provides a road map useful in negotiating the nuances behind what makes up a comprehensive program that addresses the seven elements.

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