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Updated DOJ Guidance and 6 Takeaways for Compliance Officers

On June 1, 2020, the Department of Justice’s (DOJ) Criminal Division released revisions to its Evaluation of Corporate Compliance Programs guidance for use with federal prosecutors when investigating corporations for criminal misconduct. This guidance updates the 2019 version that was covered in a previous blog post and provides insight into the DOJ’s expectations for corporate compliance programs. 

New DOJ Guidance on Evaluating Corporate Compliance Programs

The Department of Justice’s (DOJ) Criminal Division recently released a guidance document titled “The Evaluation of Corporate Compliance Programs” for use with federal prosecutors when investigating corporations for criminal misconduct. This new document updates the 2017 version in order to align with internal processes while providing additional context to the government’s analysis of a company’s compliance

Is Your Compliance Program Effective?

Having a compliance program in place is a start but having an effective compliance program is the goal. Proactively assessing the effectiveness of one’s own compliance program is better than the Department of Justice making a determination of the adequacy as a result of an investigation for alleged misconduct. To set benchmarks for an effective

Beware of Individual Liability: Yates Memo

On September 9, 2015, the Department of Justice (DOJ) Deputy Attorney General Sally Yates released a policy memorandum, titled “Individual Accountability for Corporate Wrongdoing,” also known as the “Yates Memo.” To read the full contents of the Yates Memo, click here. Essentially, the Yates Memo shifts the DOJ’s approach to fighting corporate fraud and misconduct