Why a DOJ-Aligned Compliance Training Program Matters in the UK

In 2020, the Serious Fraud Office (SFO) updated its operational guidance on evaluating compliance programmes. The recent conviction of Glencore on seven counts of bribery to a total of £280 million further solidifies the SFO’s position that a compliance program “…needs to be effective and not simply a ‘paper exercise’.”

Whilst both SFO and DOJ guidance provide transparency on how organisations are assessed, the DOJ’s ECCP document provides more substantive detail by including a series of prosecutor questions—providing compliance practitioners with a roadmap to structure our programmes for efficacy.

This guide will help you break down the themes of the latest guidance, and help you apply them to your own training program.