By John J. Carney, Margaret E. Hirce, Bari R. Nadworny and Jacqlyn Rovine
Since the U.S. Department of Justice’s (DOJ) announcement of its new compliance counsel expert in November 2015, many have been waiting patiently for additional insight into the DOJ’s emphasis on corporate compliance programs. In April 2016, the DOJ issued its Federal Corrupt Practices Act Pilot Program, again highlighting its intense focus on effective compliance programs by focusing on remediation as a factor to avoid prosecution. The Pilot Program provided criteria of an effective compliance and ethics program that would be considered during an investigation, setting benchmarks against which a company’s program would be assessed. Recently, the DOJ provided more information in its “Evaluation of Corporate Compliance Programs,” revealing critical insight about how the DOJ’s Fraud Section may evaluate a corporate compliance program during an investigation. Read more >>
