Evaluation of Corporate Compliance Programs Archives

16 Dec, 2024

Antitrust Division Revises Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations

The Department of Justice Antitrust Division’s is playing catch up to the Criminal Division on compliance leadership. DOJ’s Criminal Division has issued four separate revisions to its Evaluation of Corporate Compliance Programs. This is the Antitrust Division’s first revision to its Evaluation of Corporate Compliance Programs. The Antitrust Division’s revisions mirror many of the Criminal Division’s recent revisions with a particular focus on emerging technologies,...

DOJ Issues Revised Corporate Compliance Guidance: Consequence Management, Clawbacks and Human Resource Cooperation (Part I of III)

General

19 Mar, 2023

DOJ Issues Revised Corporate Compliance Guidance: Consequence Management, Clawbacks and Human Resource Cooperation (Part I of III)

The Justice Department is rapidly pushing corporations to a new level of compliance. We are witnessing a watershed moment – DOJ is raising the bar on expectations surrounding corporate compliance programs. It would be a mistake, however, to interpret DOJ’s recent changes as limited to compliance compensation and preservation of internal communications data. The New Push on Human Resource Cooperation When considered together, the changes...