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ARTICLE · 09 SEPTEMBER 2019

The DOJ Issues Additional Guidelines For Evaluation Of Compliance Programs

ELIG Gürkaynak Attorneys-at-Law
ELIG Gürkaynak Attorneys-at-Law
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ELIG Gürkaynak Attorneys-at-Law

ELIG Gürkaynak Attorneys-at-Law

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The DOJ has put forward a structure for the assessment of adequacy and coverage of the program's design in each company.

TurkeyCorporate/Commercial Law

The U.S. Department of Justice's Criminal Division ("DOJ") issued a new and comprehensive guidance named "The Evaluation of Corporate Compliance Programs"[1] for prosecutors to help shaping their analysis of compliance programs on April 30, 2019. This updates previous guidance issued in February 2017 and provides more detailed and concrete factors in the assessment of compliance program effectiveness, for the purposes of determining the appropriate form of resolution or prosecution, penalty and compliance obligations, if any.

These factors stem from the following three essential questions federal prosecutors are expected ask to assess whether the program actually works, is thoroughly implemented throughout the company and has preventative consequences in terms of corporate misconducts:

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