Andrew Levine is a partner at Debevoise & Plimpton LLP, who specializes in white-collar regulatory defense and internal investigations. He joins Vince Walden to discuss the compliance journey, what initiatives compliance professionals should take in 2021, and the recently updated DOJ compliance journey.
The DOJ guidance that came out in June 2020 is a step in the right direction in terms of understanding how prosecutors incorporate compliance programs into their decision-making, Andrew says. It offers real, actionable advice for building a framework for analyzing a computer program. The guidance is centered around three critical questions: Is the program well designed? Is it adequately resourced and empowered to function effectively? And, does it work in practice?
As prosecutors’ expectations for what makes up an effective compliance program continue to rise, leaders should think about enhancement opportunities. “Don’t let the perfect be the enemy of the good,” Andrew counsels. “Develop a reasonable plan, think about resourcing for implementation, think about a timetable that works, and then execute while understanding that the compliance journey is a never-ending one.”
Resources
Andrew Levine on LinkedIn