Drafts a U.S. corporate compliance program checklist anchored in DOJ ECCP, Federal Sentencing Guidelines Chapter 8, and SEC enforcement priorities. Covers governance, risk assessment, training, monitoring, reporting, domain-specific obligations, documentation, and phased implementation. Use when building, evaluating, or strengthening a compliance program, preparing for regulatory inquiry, or conducting annual program assessments.
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Drafts a U.S. corporate compliance program checklist anchored in DOJ ECCP, Federal Sentencing Guidelines Chapter 8, and SEC enforcement priorities. Covers governance, risk assessment, training, monitoring, reporting, domain-specific obligations, documentation, and phased implementation. Use when building, evaluating, or strengthening a compliance program, preparing for regulatory inquiry, or conducting annual program assessments.
Generates an assessment-ready compliance program checklist grounded in DOJ ECCP, FSG Chapter 8, and SEC frameworks, covering all major program pillars from board oversight through domain-specific controls.
Prerequisites
Company name, industry sector, and primary business activities
Existing compliance materials, audit findings, or regulatory correspondence (if any)
Compliance domains to prioritize (or confirm full-spectrum coverage)
Quick Start
Generate a professionally formatted checklist using ☐ checkboxes grouped under bold subheadings. Reference DOJ ECCP and FSG Chapter 8 explicitly in the preamble. Tailor domain-specific sections to the company's actual regulatory profile — not all domains apply equally.
Checklist Sections
1. Governance & Oversight
Board/Committee
Element
Standard
Board compliance oversight charter
Caremark duties (In re Caremark Int'l, Del. Ch. 1996)
Audit/compliance committee with direct CCO access
FSG §8B2.1(b)(2)
Board-level compliance reporting (≥ quarterly)
DOJ ECCP §I
Board training on red flags and regulatory trends
DOJ ECCP §I
Chief Compliance Officer — must have: organizational independence from revenue functions, direct CEO/board reporting line, adequate budget/staffing/authority, documented mandate and delegation matrix.
Policy Framework — each policy requires approval authority, effective date, version control, distribution log, employee acknowledgment, and review cycle (≤ 3 years):
Policy
Key Requirements
Code of Conduct
Values, escalation paths, annual certification
Anti-Corruption / Anti-Bribery
FCPA compliance, foreign official interactions
Gift & Entertainment
Monetary thresholds, pre-approval for government officials
Periodic — annual compliance audit, targeted high-risk audits, transaction sampling, control effectiveness testing, remediation follow-up within agreed timelines.
Independence — internal audit reports to audit committee (not management), testing independent from business units under review, work papers per IIA Standards.
Anti-retaliation — track employment actions on reporters (12-month lookback), follow-up at 60/120 days, zero-tolerance with disciplinary matrix.
6. Domain-Specific Compliance
Include only domains relevant to the company's regulatory profile.
Employment — FLSA classification/overtime, Title VII/ADA/ADEA policies and training, OSHA hazard programs (Form 300), FMLA/state leave, FCRA background checks, contractor classification (IRS 20-factor; state ABC tests).
Data Privacy & Cybersecurity — CCPA/CPRA, VCDPA, CPA + applicable state laws; privacy notice and consumer rights workflows; data minimization and retention; vendor DPAs; breach notification (state matrix, 30–72 hours); HIPAA/GLBA/GDPR where applicable; NIST CSF or equivalent.
Financial Controls — SOX §302/§404 (disclosure controls, ICFR); segregation of duties; revenue recognition (ASC 606); financial close procedures; anti-fraud program (ACFE framework).
Contracts & Procurement — review thresholds/approval matrix, standard templates, vendor due diligence, government contract compliance (FAR/DFARS), obligation tracking.
Antitrust — HSR filing thresholds [VERIFY current amount], competitor interaction policy (no price-fixing/market allocation/bid-rigging), resale price maintenance guardrails, trade association pre-clearance, annual sales/marketing training.
7. Documentation & Recordkeeping
Record Type
Retention
Compliance policies (all versions)
Perpetual
Training completion records
7 years
Audit work papers
7 years (SOX)
Investigation files
Statute of limitations + 3 years
Risk assessments
7 years
Board/committee compliance minutes
Perpetual
Employment records
3–7 years (varies by law)
Environmental permits/monitoring
Permit duration + 5 years
Litigation hold procedures tested annually. Privileged materials clearly marked; sensitive investigations under counsel direction. Centralized system with access controls and audit trail.
8. Implementation Roadmap
Phase 1 — Assessment (0–60 days): Gap analysis, risk assessment, executive/board commitment and budget.
Phase 2 — Foundation (60–180 days): Appoint CCO, draft Code of Conduct and priority policies, launch hotline and investigation procedures, deploy initial training.
Phase 3 — Expansion (180–365 days): Full training rollout, monitoring system configuration, first annual audit, metrics dashboard operational.
Phase 4 — Optimization (ongoing): Annual DOJ ECCP self-assessment (well-designed? earnestly applied? works in practice?), peer benchmarking, regulatory monitoring (DOJ, SEC, FTC, DOL, EPA, state AGs).
KPIs
Leading
Lagging
Training completion (target: 100%)
Violations/incidents count
Policy acknowledgment rate
Regulatory findings/citations
Hotline utilization
Audit deficiencies
Risk assessment coverage (% of BUs)
Investigation cycle time
Third-party due diligence completion
Repeat findings rate
Guidelines
Reference DOJ ECCP and FSG Chapter 8 explicitly as the primary evaluative frameworks
Privilege: recommend sensitive investigation work under attorney direction
Self-disclosure requires separate legal analysis — flag but do not resolve
Verify HSR thresholds and state privacy law applicability at time of use [VERIFY]
SOX §302/§404 is non-negotiable for public companies; note private analogues where useful
GDPR applies only if company processes EU resident data — confirm before including
Troubleshooting
Unclear regulatory profile: Start with governance, risk assessment, and reporting sections. Add domain-specific sections as regulatory exposure is confirmed.
Company spans multiple jurisdictions: Build a jurisdiction matrix first. Layer state/local requirements onto the federal baseline per domain.
Existing program assessment vs. new build: For assessments, use the checklist as a gap analysis tool — score each item as implemented/partial/missing. For new builds, follow the phased roadmap in Section 8.
Privilege concerns with investigation documentation: Flag that all investigation work product should be created at counsel's direction and clearly marked as privileged. Do not draft investigation protocols that waive privilege.
