OFF THE WIRE
On December 1, the Department of Justice’s (DOJ) Office of the Inspector General (OIG) released a report on the FBI’s Integrity and Compliance Program (ICP), which was established in 2007 to ensure there were processes and procedures in place that promote FBI compliance with both the letter and the spirit of the law.
The OIG report concludes, among other things, that the Bureau—through our ICP—has “started to reduce the FBI’s risk of legal non-compliance, and that the ICP has the potential to further reduce risk by identifying risks and making operational and policy changes necessary to mitigate them before they become problems.” The report also says that our Office of Integrity and Compliance (OIC), which oversees the ICP, has been beneficial to our efforts to monitor and enhance compliance with legal requirements, and that “other agencies may wish to consider implementing a similar kind of program.”
The FBI’s ICP, according to Patrick Kelley, OIC Assistant Director, was modeled after corporate compliance programs and involves a system of internal controls geared to prevent and detect potential violations of the law. Risks are identified and prioritized, mitigation plans are developed and implemented, and the process is monitored and audited to make sure the identified risks have actually been reduced. “We operate in a very complex legal environment,” said Kelley, “and our program works to ensure that the FBI and its employees are in compliance with all of the laws, regulations, and policies that govern our activities, operations, and programs across the Bureau.”
