AAG Caldwell Provides Guidance On Adequate Compliance Programs

Recently confirmed Assistant Attorney General of the U.S. Department of Justice Criminal Division, Leslie Caldwell, has laid out her views as to what comprises the "hallmarks of good compliance programs." In her new position, AAG Caldwell will repeatedly be in the position to decide whether corporate compliance programs are sufficient when making charging and settlement decisions and so her views on the subject are of particular import.

During an October 1, 2014 speech at the 22nd Annual Ethics and Compliance Conference, Caldwell highlighted the following:

• Companies must exhibit a high-level and visible commitment to compliance from senior management;
• Companies should have written policies in place that enables employees to, as easily as possible, figure out what to do or not do when faced with an ethical judgment call;