The Justice Department “listens and learns” from companies and compliance practitioners.  As part of every enforcement action, DOJ prosecutors review and assess compliance programs in accordance with the standards explained in its recent Evaluation of Corporate Compliance Programs issued on April 30, 2019. DOJ prosecutors have seen it all when it comes to compliance.  Prosecutors have observed compliance train wrecks – companies that have suffered...

It is easy to get swept up into compliance trends, prognosticators of the future, and future compliance terms such as “artificial intelligence,” or “blockchain.”  Do not get me wrong, these are the terms for the future and eventually they will be part of common compliance conversations. But sometimes we need to get back to basics.  In some cases, Chief Compliance Officers need to remind themselves...