Corporate
Mar. 1, 2024
Keeping a watchful eye on the Corporate Compliance Program rule breakers
The Department of Justice expects companies to disclose misconduct within a reasonably prompt time after becoming aware of it, even before completing an internal investigation.
Stephanie Yonekura
Partner, Hogan Lovells US LLC
Phone: (310) 785-4600
Email: stephanie.yonekura@hoganlovells.com
UCLA SOL; Los Angeles CA
Ann Kim
Partner, Hogan Lovells
Alicia M. Matarese
Associate, Hogan Lovells US LLP
Phone: (310) 785-4600
In 2023, the U.S. Department of Justice announced revisions to its Corporate Enforcement Policy and made several revisions to its Evaluation of Corporate Compliance Programs. The revisions were implemented with the goal of encouraging early voluntary self-disclosures, “extraordinary” cooperation, and effective compliance programs. While the intended goal of the policies is clear, the details of how companies will benefit from these revised programs are yet unknown. Th...