Category

Compliance

12 June 2019

Principal Deputy Associate Attorney General Discusses DOJ’s Corporate Enforcement Priorities, Focus on Corporate Compliance

At the recent Compliance Week Annual Conference, Principal Deputy Associate Attorney General Claire McCusker Murray delivered extensive remarks on DOJ’s corporate enforcement priorities.  Of particular note, Murray discussed a number of policy reforms focused on promoting and incentivizing corporate compliance and cooperation.

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03 May 2019

DOJ Publishes New Guidance on Evaluating Corporate Compliance Programs

On April 30, the Criminal Division of the U.S. Department of Justice (DOJ) released a new guidance document titled “The Evaluation of Corporate Compliance Programs,” which updates a prior version of the guidance first issued in February 2017 (previously analyzed here). The new guidance provides additional insights into how DOJ will assess the effectiveness of a company’s overall compliance program in an enforcement action, focusing on the program’s design, implementation and effectiveness.

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22 June 2018

Acting Associate Attorney General Discusses Trump Administration FCA Enforcement Policy

On June 14, 2018, at the ABA’s National Institute on the Civil False Claims Act and Qui Tam Enforcement, Acting Associate General, Jesse Panuccio, delivered wide-ranging remarks on the False Claims Act. Of particular interest, AAG Panuccio discussed several recent high profile enforcement priorities of the Trump Administration. (more…)

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03 March 2017

Department of Justice Publicizes Questions Used to Evaluate Corporate Compliance Programs

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.

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