Gatekeepers: Safeguarding the Keys to the Compliance Kingdom

The following is a guest post written by Diana Trevley, Chief of Global Services, Spark Compliance Consulting

The Department of Justice’s recently released Evaluation of Corporate Compliance Programs Guidance Document (“Guidance”) provides prosecutors with a list of questions to consider asking when investigating a company’s compliance failures and determining whether to bring charges.  By publishing these questions, the Guidance also provides companies with specific information on what actions, taken together, constitute an effective compliance program.  Included in the document are three questions about gatekeepers:

“Gatekeepers – What, if any, guidance and training has been provided to key gatekeepers in the control processes (e.g., those with approval authority or certification responsibilities)? Do they know what misconduct to look for? Do they know when and how to escalate concerns?”

This has some compliance officers wondering, what, pray tell, exactly is a gatekeeper?…