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Episode 89 -- DOJ Issues New Guidance on Evaluation of Corporate Compliance Programs
In recently released updated guidance, the Antitrust Division (“Antitrust Division”) of the U.S. Department of Justice (“DOJ”) outlined how its prosecutors will assess corporate compliance programs when conducting criminal...more
On November 12, 2024, the DOJ Antitrust Division updated its Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations (ECCP), which was initially issued in 2019. The ECCP provides guidance to...more
Last month, the U.S. Department of Justice (“DOJ”) quietly updated its March 2023 guidance on the evaluation of corporate compliance programs. Of course, DOJ did not conduct a major rewrite, but interestingly, the updated...more
On September 23, 2024, the U.S. Department of Justice (“DOJ”) released updates to its Evaluation of Corporate Compliance Programs (“ECCP”) guidance. In a move that surprised no one (especially if companies have been reading...more
On July 22, 2020, the Federal Trade Commission ("FTC") issued revised FAQs regarding the Children's Online Privacy Protection Act and the FTC Rule issued thereunder (together "COPPA"). The COPPA FAQs provide practical...more
I recently had the opportunity to visit with Stephen Martin, Partner at StoneTurn, to consider some of the impacts on corporate compliance programs from the recently released 2020 Update to the Department of Justice’s (DOJ)...more
In June, the Department of Justice (DOJ) published an Update to their Evaluation of Corporate Compliance Programs (2020 Update) which set out to provide additional clarity on how enforcement officials will evaluate an...more
CEP Magazine (August 2020) - In June, the Department of Justice made small changes to the Evaluation of Corporate Compliance Programs guidance document that reflect the department’s growing understanding of how compliance...more
Report on Supply Chain Compliance 3, no. 14 (July 23, 2020) - The United States Department of Justice (DOJ) released an update to its guidance document, Evaluation of Corporate Compliance Programs, which is based on...more
On June 1, 2020, the Department of Justice (“DOJ”) issued an updated version of its “Evaluation of Corporate Compliance Programs” (the “DOJ Guidance”), available here. The DOJ Guidance is an update to guidance first issued by...more
Earlier this month, the Criminal Division of the United States Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs guidance. In considering enforcement actions against companies, prosecutors...more
The United States Department of Justice (DOJ) released updated guidance regarding its evaluation of corporate compliance programs on June 1, 2020. The release comes just over a year since the guidance was last updated in...more
The Department of Justice issued additional clarification and revised guidance on June 1, 2020, for corporate program compliance programs. The additional guidance doesn’t introduce substantive changes; however, it emphasizes...more
On April 30, 2019, Assistant Attorney General Brian Benczkowski unveiled an update to the Department of Justice’s Evaluation of Corporate Compliance Programs during a speech in Dallas, Texas. In issuing the new document (the...more
On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...more
Companies must now address three questions proactively. On April 30, 2019, the DOJ’s Criminal Division issued updated guidance on how it will evaluate corporate compliance programs in its charging decisions going forward....more
The Situation: On April 30, 2019, the U.S. Department of Justice ("DOJ") released an updated version of its guidance document, "Evaluation of Corporate Compliance Programs," in an effort to "better harmonize" the document...more
Last week, the US Department of Justice (DOJ) released its updated guidance on how prosecutors should evaluate corporate compliance programs. The revised guidance reiterates and expands on the hallmarks of successful...more
The U.S. Department of Justice (DOJ) has released updated guidance on evaluating corporate compliance programs. The Evaluation of Corporate Compliance Programs updates prior guidance that was released by DOJ in February 2017....more
The DOJ’s recently updated guidance poses helpful questions for UK corporates evaluating the effectiveness of their internal compliance programmes. It is well known that a corporate’s failure to prevent offences can be...more
On April 30, 2019, Assistant Attorney General Brian Benczkowski unveiled an update to the Department of Justice’s Evaluation of Corporate Compliance Programs during a speech in Dallas, Texas.[i] In issuing the new document...more
We are in an exploration of the recently released Evaluation of Corporate Compliance Programs – Guidance Document (2019 Guidance), which was announced (ECI speech) by Assistant Attorney General Brian Benczkowski at the Ethics...more