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ARTICLE · 11 JUNE 2020

Updated DOJ Guidance On Evaluation Of Corporate Compliance Programs Provides Additional Detail To The Existing Framework For Program Assessment

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On Monday, June 1, 2020, the Department of Justice (DOJ) Criminal Division published updates to its guidance on the factors that federal prosecutors should consider when assessing the...

United StatesCompliance
Mahnu Davar
Mahnu Davar
Wilson D. Mudge
Wilson D. Mudge
John N. Nassikas
John N. Nassikas
John Tan
John Tan
Samuel Witten
Samuel Witten
Daniel Bernstein
Daniel Bernstein
Lindsey D. Carson
Lindsey D. Carson
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On Monday, June 1, 2020, the Department of Justice (DOJ) Criminal Division published updates to its guidance on the factors that federal prosecutors should consider when assessing the effectiveness of corporate compliance programs for the purposes of charging decisions, sentencing recommendations, and determining reporting and monitoring requirements as part of a corporate resolution (2020 Compliance Guidance). The new version primarily makes clarifications and adds technical guidance to the "Evaluation of Corporate Compliance Programs" guidance document that DOJ released in April 2019.1 This latest version continues to reflect the fact-specific compliance program analysis familiar to experienced defense counsel and compliance officers, but several revisions are noteworthy.2

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