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Episode 89 -- DOJ Issues New Guidance on Evaluation of Corporate Compliance Programs
On 22 January 2024, the Financial Reporting Council (FRC) published its much-anticipated revisions to the UK Corporate Governance Code (the Code) which was followed on 29 January 2024 by revised guidance on the Code. In this...more
Companies with business operations in Japan should review due diligence procedures and internal policy regarding small facilitation payments to ensure they are consistent with new guidance from METI. In May 2021, the...more
A. Adoption in 1962 - The SEC has regulated custodial practices of investment advisers since 1962, when it first adopted rule 206(4)-2 (the “Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”) under...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
In June, the U.S. Department of Justice updated its Evaluation of Corporate Compliance Programs Guidance (“Guidance”). While the Guidance is intended to assist prosecutors by providing factors to consider in evaluating the...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
On June 1, 2020, the US Department of Justice ("DOJ") published an updated version of its guidance on the "Evaluation of Corporate Compliance Programs" (the "Guidance"), which was first published in February 2017. When...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
New guidance issued by the U.S. Department of Justice (DOJ) is the latest confirmation of the importance of implementing a robust compliance program that is not simply well-designed, but also effective....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
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
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
• The NFA has determined that registered CPOs must implement an internal controls system and highlighted best practices for such a framework. • In response to certain frequently asked questions, the NFA has also updated its...more