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ARTICLE · 17 JUNE 2019

DOJ's Recent Enforcement Policy Changes Further Incentivize Effective Corporate Compliance Programs

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On May 20, 2019, Principal Deputy Associate Attorney General Claire McCusker Murray addressed the annual Compliance Week Conference regarding the new enforcement policies previously announced

United StatesCorporate/Commercial Law
Akin Gump Strauss Hauer & Feld LLP
Akin Gump Strauss Hauer & Feld LLP
A. Michael Warnecke
A. Michael Warnecke
Corey W. Roush
Corey W. Roush
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Key Points:

  • The DOJ recently highlighted the benefits of robust corporate compliance programs and its interest in incentivizing such programs as the common thread running throughout its recent enforcement policy changes, including the False Claims Act (FCA) credit policy announced on May 6, 2019, and the criminal enforcement reforms announced on April 30, 2019.
  • Company compliance programs play a significant role in DOJ enforcement, not only in determining the nature and extent of the credits that companies can earn, but also in determining whether a civil or criminal enforcement action will proceed at all.
  • In the FCA context, the DOJ considers the nature and effectiveness of a company’s compliance program in evaluating whether the FCA applies.

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