Key Considerations and Updates for Life Sciences Companies -

On April 30, 2019, the Criminal Division of the U.S. Department of Justice (DOJ) issued updated guidance for white-collar prosecutors on evaluating the effectiveness and adequacy of corporate compliance programs (DOJ Compliance Guidance). This new guidance reorganizes, clarifies and adds details to the DOJ Fraud Section’s February 2017 guidance addressing compliance program evaluation. DOJ also seeks to better harmonize and consolidate existing Department standards with this new guidance.

These latest updates from DOJ now apply beyond the Fraud Section to the entire Criminal Division. They also serves as a roadmap for prosecutors, as well as boards of directors, management, compliance officers and legal counsel, in analyzing compliance programs.

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