DOJ Publishes New Guidance For Compliance Programs

On February 8, 2017, the Fraud Section of the U.S. Department of Justice (the "DOJ") published a guide for companies called "Evaluation of Corporate Compliance Programs" (the "Guidance"). The Guidance is composed of common questions that the DOJ asks when evaluating a company's compliance program. While the Guidance questions are largely based on familiar sources, such as the United States Sentencing Guidelines and the "Principles of Federal Prosecution of Business Organizations" in the United States Attorney's Manual,¹ the questions provide a greater degree of detail and insight into the DOJ's process for evaluating compliance programs.

Areas Covered

The Guidance focuses on three overarching areas: (1) company culture, (2) compliance structure and resources, and (3) the effectiveness of company policies and procedures.