The U.S. Department of Justice (DOJ) announced an update to its earlier
guidance on how the DOJ will evaluate the effectiveness of a
company's corporate compliance program. The updated compliance
guideline ("Updated Guidance") is twice the length of the
original, and utilizes a more instructive approach, serving as a
roadmap to prosecutors, and prudent companies. Although not binding
on DOJ prosecutors, the Updated Guidance will certainly impact the
way the DOJ evaluates corporate compliance programs during
investigations and settlement negotiations.
Read our summary and analysis of the
DOJ’s 18-page Updated Guidance, in which we focus on the
important lessons a company can learn about the key elements
necessary for a robust and effective compliance program.
