The U.S. Department of Justice (DOJ) announced an update to its earlier guidance on how the DOJ will evaluate the effectiveness of a company’s corporate compliance program. The updated compliance guideline (“Updated Guidance”) is twice the length of the original, and utilizes a more instructive approach, serving as a roadmap to prosecutors, and prudent companies. Although not binding on DOJ prosecutors, the Updated Guidance will certainly impact the way the DOJ evaluates corporate compliance programs during investigations and settlement negotiations.
Read our summary and analysis of the DOJ’s 18-page Updated Guidance, in which we focus on the important lessons a company can learn about the key elements necessary for a robust and effective compliance program.