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ARTICLE · 27 SEPTEMBER 2024

DOJ Updates Its Corporate Compliance Programs Guidance

Womble Bond Dickinson
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On September 23, 2024, the Criminal Division of the U.S Department of Justice ("DOJ") released revised Evaluation of Corporate Compliance Programs guidance ("September 2024 Guidance)1, last updated in March 2023.

United StatesCriminal Law
Luke Cass
Luke Cass
Audrey N. Karman
Audrey N. Karman
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On September 23, 2024, the Criminal Division of the U.S Department of Justice ("DOJ") released revised Evaluation of Corporate Compliance Programs guidance ("September 2024 Guidance)1, last updated in March 2023.

The latest guidance covers three primary areas of on-going interest for the DOJ: (1) how companies are identifying and mitigating emerging risks related to new technologies, including artificial intelligence (AI); (2) how companies are encouraging employees to report misconduct; and (3) whether there are appropriate resources and access to data allowing for companies to measure the effectiveness of their compliance programs.

The Evaluation of Corporate Compliance Programs guidance serves as a roadmap for prosecutors and corporations, setting forth factors and questions for evaluating the effectiveness of a company's compliance program. These considerations aid prosecutors in determining whether and to what extent a company should be penalized in

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