Clifford Chance
US DOJ Publishes Updated 'Guidance Document' on 'Evaluation of Corporate Compliance Programs'
6 May 2019
On April 30, 2019, the US Department of Justice, Criminal Division, published an updated "Guidance Document" on "Evaluation of Corporate Compliance Programs."
The Guidance provides prosecutors, and thereby companies, with specifics around requirements for corporate compliance programs which DOJ will evaluate when conducting an investigation of a corporation. This evaluation will inform charging decisions and the form of resolution of a matter, and factor into the determination of the appropriate monetary penalty and compliance obligations. DOJ helpfully notes that its Guidance is not intended as a "one size fits all" for developing a corporate compliance program, but nonetheless provides companies with a helpful "checklist" to consider when both designing a program and importantly, when presenting the program to DOJ in connection with an investigation or settlement negotiation.
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