The DOJ has raised the bar for corporate compliance programs, with recent updates demanding new attention to AI risks and electronic communications. StoneTurn’s Jonny Frank breaks down the essential elements of a DOJ-ready program and explains why 2025 is the year to get serious about implementation.
Which is more likely: a company coming under DOJ investigation or a commercial building being destroyed by fire? Answer: DOJ investigation.
Don’t believe me? Destruction from fire is less frequent due to modern fire safety measures and rapid response times. According to the National Fire Protection Association, there were about 130,000 non-residential building fires in the US in 2022, a low probability per building, given there are almost 6 million commercial buildings in the US. On the contrary, the range of issues that trigger DOJ investigations is vast, and the proliferation of government whistleblower programs has increased the likelihood of detection.
Yet, despite the statistical differences, companies are more willing to install fire extinguishers and buy insurance than invest in compliance programs that satisfy DOJ “Evaluation of Corporate Compliance Program” guidance. Just as building owners buy fire insurance and keep fire extinguishers on hand — not expecting a fire but ready for the…
