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In a new memo from U.S. DOJ Deputy Attorney General Lisa Monaco outlining further revisions to corporate criminal enforcement policies, the word “culture” appears 13 times.

"PROSECUTORS SHOULD EVALUATE THE CORPORATION'S COMMITMENT TO FOSTERING A STRONG CULTURE OF COMPLIANCE AT ALL LEVELS OF THE CORPORATION—NOT JUST WITHIN ITS COMPLIANCE DEPARTMENT," the memo says.

In addition to previously published guidance, the memo lists two factors for prosecutors to consider: (1) “compensation structures that promote compliance” and (2) “use of personal devices and third-party applications.” TRACE supports hundreds of companies around the world in maintaining an effective compliance program through access to training, compliance resources, risk mitigation tools and community. Below are a few resources that can help you foster a culture of business ethics:

• Keep the human consequences of bribery front and center of messaging, emphasizing that unethical business decisions can devastate communities and individuals. If you missed our Corruption Files series, watch it here.
• Build a culture where speaking up is not just accepted, but expected. TRACE members have access to webinars and events around the world, including an upcoming webinar that will provide a firsthand perspective of Weatherford’s approach to embedding compliance and ethics throughout the employment lifecycle. Become a TRACE member to access events, webinars and a library of recorded content.
• Make sure you have the basics covered. Is your compliance program “well designed, adequately resourced, empowered to function effectively, and working in practice”? We’ve paired these concepts with helpful resources designed for both compliance teams and third parties in our new Compliance Program Starter Kit, available on the members-only TRACE Resource Center.
• Raise the standards of your compliance training program while reducing cost and time. Included with TRACE membership, you can deploy our multilingual eLearning courses throughout your entire value chain. To demo our new courses and mini modules on topics including ESG, data privacy and speaking up in the workplace, write to [email protected].

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TRACE membership is designed to help you build and maintain a strong culture of compliance throughout your organization. Membership benefits include unlimited access to our eLearning, Resource Center, and risk management tools. In addition, benefit from complimentary attendance to webinars and events, networking and benchmarking opportunities, and more. Write to [email protected] to learn more about membership benefits.