In addition to the United States Department of Justice’s recently issued guidelines related to cooperation in FCA enforcement actions, the Department of Justice (DOJ)’s Criminal Division recently revised its guidance pertaining to assessment of corporate compliance programs. The revised guidance will inform DOJ’s approach to criminal investigations, charging decisions, plea agreements, and sentencing in cases involving alleged corporate noncompliance or wrongdoing.
DOJ previously published guidance on its evaluation of corporate compliance programs in 2017. As with the previous version, the revised guidance eschews a “rigid formula” for assessing compliance programs.Continue Reading DOJ Asks “Fundamental Questions” of Corporate Compliance Programs