There’s good and bad news out there for compliance departments, and it’s also the same news: Governments now very much appreciate strong compliance programs.

On the one hand, that is very good (if not great!) news. Prosecutors expect organizations to have strong, well-resourced, and effective compliance efforts. Companies that don’t will have lots of explaining to do, and likely much higher penalties.

In the U.S., proof can be found in the U.S. Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs, as well as the November 2023 General Compliance Program Guidance issued by the U.S. Department of Health and Human Services Office of Inspector General. Both texts demonstrate that the government understands what makes for an effective program.