SFO Guidance on evaluating compliance programmes
/The UK's Serious Fraud Office has published new guidance on how to asses the effectiveness of an organisation's compliance programme. The chapter 'Evaluating a compliance Programme' was added on 17 January to the SFO Operational Handbook.
The SFO's Operational Handbook is aimed at SFO staff, and sets out (in redacted form in the externally published version) standard processes, instructions and guidance on the conduct of SFO casework.
It's not good enough, and more is needed to show that adequate procedures is really a viable defence. The SFO's Guidance doesn't do what the DOJ document does, which is get to the reality of what is actually happening with a compliance programme versus what words are written on the pages of the policies.
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