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Podcast: Corruption Crime & Compliance
Episode: Episode 241 -- Continuous Improvement, Testing and Auditing of Your Ethics and Compliance Program
Description: The Justice Department and various regulatory agencies continue to emphasize the importance of continuous improvement, testing and review as part of robust assessment procedures in an effective compliance program. The Treasury Department's Office of Foreign Asset Control has specifically stated that a sanctions compliance program should include "a comprehensive, independent, and objective testing or audit function" so that a company can determine "how their program[] [is] performing and should be updated, enhanced, or recalibrated to account for a changing risk assessment or sanctions environment." The Health and Human Services -- Office of Inspector General has made similar statements underscoring th...