The U.S. Department of Justice has updated its guidance on corporate compliance programs. In its update, the DOJ offers practitioners further insight on how the DOJ evaluates compliance programs by refining key terms and providing more context. The DOJ has made clear that compliance should not be thought of as a static exercise. Instead, any program needs to be evaluated and refreshed when additional data becomes available ensuring that the compliance program is robust and flexible. Armed with this newly refined direction, prosecutors have authority to reference official guidance when evaluating a corporation’s risk functions, and corporations would do well to take note.
Read the full Perkins Update here: