DOJ Issues New Guidance On Effective Compliance Programmes

In February 2017, the U.S. Department of Justice's Fraud Section issued its evaluation of corporate compliance programmes. The evaluation provides a detailed overview of sample questions addressed by the DOJ in evaluating these programmes in the context of investigations. While the DOJ does not provide innovative insights into the appropriate structure of corporate compliance programmes, the guidance contained in the evaluation document – jointly with other available tools such as the recently published ISO 37001 – can assist multinational companies in reassessing the design of their programmes, as well as those of their JV partners and target companies in M&A transactions. Companies should therefore pay close attention to this evaluation document when creating and implementing their compliance programmes.