Evaluation of Corporate Compliance Programs
An Updated Guidance from the Criminal Division of the Department of Justice for US Corporations to Assess Compliance Programs
The Evaluation of Corporate Compliance Programs Guidance that was originally published in 2017 (“the 2017 Guidance”) served as the first document specifically dedicated to the topic of corporate compliance published by the Criminal Division within the Department of Justice (“DOJ”). The 2017 Guidance outlined 11 topics for the evaluation of corporate compliance programs, together with questions in respect of each topic. Although this 2017 Guidance supported the existing compliance guidelines, it did not outline new guidelines for corporations to refer to during a self-assessment of their compliance frameworks. The 2017 Guideance included more than 100 questions which prosecutors could pose to organizations as part of the evaluation process.
On April 30, 2019, the DOJ published the Updated Guidance (Updated Guidance) in respect of the evaluation of corporate compliance programs. The goal of the Updated Guidance is to assist prosecutors in evaluating corporate compliance programs, and provides insight into their criteria that corporations operating in highly regulated industries should review in order to update their compliance plans. The new guideline updates the 2017 Guidance, and is important for organizations of all sizes and across all industries.
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