DOJ Three Questions: Design, Power, Proof
Apply the DOJ three-question lens to judge whether a compliance program is real in operation.
A compliance program is not judged only by what exists. It is judged by what it can do. The DOJ lens is powerful because it asks three different questions. Design asks whether the program matches the company risk profile. Power asks whether compliance has enough independence, access, and resources to influence real choices. Proof asks whether the system works when pressure arrives. These are not interchangeable. A risk assessment without resources becomes a wish list. A strong reporting line without monitoring misses weak signals. A training program without investigation learning repeats old examples while new misconduct routes develop. The three…
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