In this 5-part podcast series I visit with Eric Feldman, Senior Vice President of AMI. We look at the Department of Justice Evaluation of Corporate Compliance Programs, (the “2019 Guidance”), which was released in April 2019. Over the next five podcasts we will explore what the 2019 Guidance changes are from the Evaluation of Corporate Compliance Program, released in February 2017, the structure and emphasis of the 2019 Guidance and what it means for the compliance practitioner going forward. In Episode 3, we consider the question “Is it being effectively implemented?” We look at commitment by top management, autonomy and resources for the CCO and compliance function and incentives and disciplinary measures taken by an organization.