On Feb. 8, the Fraud Section of the Department of Justice (DOJ) publicized new guidance, titled “Evaluation of Corporate Compliance Programs.” The guidance sets forth sample questions prosecutors may ask when evaluating a company’s compliance program in the context of a criminal investigation. This document is the latest direction released under the Fraud Section’s “compliance initiative,” which began when the Fraud Section hired Hui Chen as a full-time compliance expert in November 2015. This guidance provides insights into how the DOJ will assess the effectiveness of a company’s overall compliance program, with a specific focus on how the program will be viewed in the context of the underlying misconduct identified. See http://www.sidley.com/news/2017-02-21_fcpa_update.
https://fcablog.sidley.com/wp-content/uploads/sites/5/2022/08/sidleyLogo-e1643922598198.png 0 0 Kristin Graham Koehler https://fcablog.sidley.com/wp-content/uploads/sites/5/2022/08/sidleyLogo-e1643922598198.png Kristin Graham Koehler2017-03-03 12:55:552017-03-03 12:55:55Department of Justice Publicizes Questions Used to Evaluate Corporate Compliance Programs