Under Hallmark Nine of Ten Hallmarks of an Effective Compliance Program as articulated in the 2012 FCPA Guidance, it stated, “Finally, a good compliance program should constantly evolve.” This insight was carried forward in the Department of Justice’s 2017 Evaluation of Corporate Compliance Programs which listed three types of continuous improvement: (1) internal audit, (2) control testing, and (3) evolving updates; each was category further refined with multiple attendant questions.

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