For crimes such as tax-related offenses, environmental protection, work safety, data security, and infringement of intellectual property rights, procuratorial organs apply the compliance inspection system to enterprises involved in cases. This skill assists lawyers in reviewing corporate compliance rectification drafts to ensure they meet the requirements of the third-party supervision and evaluation mechanism.
🛡️ Pre-check: Absolute Anonymization
Before beginning any processing, perform a strictanonymization check. If the input text is found to contain the real name of an enterprise involved in a case or an entrepreneur:
- Stop execution immediately.
- Reply requiring the use of placeholders (such as [a certain chemical enterprise], [legal representative A]).
📋 Workflow
Phase One: Matching the Crime Involved in the Case with the Compliance Target
Identify the crime suspected by the enterprise (such as the crime of falsely issuing special VAT invoices, the crime of environmental pollution, or the crime of infringing on citizens' personal information). Clarify that the core target of compliance rectification should be "the internal management loopholes of the enterprise that gave rise to the crime."
Phase Two: Compliance Plan Review (Compliance Plan Review)
Using the Measures for Compliance Construction, Evaluation and Review of Enterprises Involved in Cases (Trial) (Quan Ting Lian Fa [2022] No. 13) as the standard (see details in references/criminal-compliance-core.md), the review dimensions include:
- Specialized compliance vs. comprehensive compliance: Does the rectification plan accurately focus on the field of the suspected crime (specialized), while appropriately taking into account other potential risks?
- Organizational structure: Has an independently operating compliance committee or compliance officer been established?
- Institutional development: Are there targeted rules and regulations (such as a tax-related risk isolation wall or a pre-approval process for environmental impact assessments)?
- Operating mechanism: Does it include compliance reporting channels, compliance performance assessment, and violation disciplinary measures?
- Separation mechanism: Has the responsibility of the enterprise involved in the case and the entrepreneur (individual) involved in the case been effectively separated?
Phase Three: Identifying Blind Spots and Proposing Improvement Suggestions
List the missing "standard" elements in the plan (for example, many enterprises overlook compliance review of third-party suppliers, or fail to design a whistleblower protection mechanism).
Output Format
## 一、 涉案合规基础定性
- **涉嫌罪名**：...
- **合规领域**：...
## 二、 合规计划实质性审查 (差距分析)
| 评估维度 | 当前计划内容 | 存在盲点/不足 | 改进建议 |
| :--- | :--- | :--- | :--- |
| 组织与保障 | ... | ... | ... |
| 风险识别与管控制度 | ... | ... | ... |
| 监督、举报与惩戒机制 | ... | ... | ... |
## 三、 迎检（第三方监督评估）核心提示
针对该类犯罪的第三方检查，通常会着重抽查哪些实质性证据（例如培训记录、
员工访谈、内部审批流截图），提醒企业切忌"纸面合规"。
## 四、 程序提示
- 合规考察的启动节点（审查起诉阶段为主）、考察期限、与认罪认罚的衔接。
- 各地第三方机制管委会评估细则差异 `[需核实]`。
At the end of the output, attach the review notes, disclaimer, and next-step decision tree specified in CLAUDE.md.