Steven D Gordon is Partner in Holland & Knight's
Washington D.C. office
Rodney M Perry is Associate in Holland &
Knight's
Washington D.C. office
Robert K Tompkins is Partner in Holland &
Knight's
Washington D.C. office
Kwamina Thomas Williford is Partner in Holland &
Knight's
Washington D.C. office
Last week, the DOJ Criminal Division published a guidance
document entitled "Evaluation of Corporate Compliance
Programs" (ECCP). This document is meant to assist prosecutors
in determining what credit should be given to a corporation for
having an effective compliance program when prosecutors decide
whether to bring charges, what charges to bring, what amount of
penalties to seek, or whether to impose a monitorship or reporting
obligations on a corporation. The document is equally useful to
companies that want to assess their current compliance program and
determine whether any changes need to be made.
