What does the U.S. Department of Justice (DOJ) expect of a corporate compliance program? How does the DOJ evaluate whether a compliance program meets those expectations? And how can a company proactively shape its compliance program to meet those expectations? In late April 2019, the DOJ’s Criminal Division released an updated version of its “Evaluation of Corporate Compliance Programs” (the “revised Guidance”), which helps prosecutors and companies alike answer those questions. This article will briefly explore the history of the revised Guidance and highlight some of its most important aspects.
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