The U.S. Department of Justice updates roadmap to an effective compliance program

On June 1, 2020, the U.S. Department of Justice (DOJ), Criminal Division, updated its guidance on the "Evaluation of Corporate Compliance Programs," providing increased clarity on some of the key questions prosecutors will ask in assessing the adequacy of corporate compliance programs when making charging, sentencing, and plea and settlement decisions.

These updates fall into three main categories. First, the DOJ made a subtle yet significant clarification to its three "fundamental questions." Second, it provided more detail on the way it makes individualized determinations in assessing compliance programs. Third, throughout its guidance, the DOJ has included more specific questions it will ask about the nuances of a company's programming, which provides greater insight into the DOJ's expectations. Companies can look to these revisions for guidance on two fronts: to proactively create or enhance their compliance programs and to effectively advocate before the DOJ in the context of a criminal investigation.

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