Tips For Using DOJ Guidance In A Compliance Program

Law360 (May 22, 2019, 4:37 PM EDT) -- Since its release on April 30, much has been written about the U.S. Department of Justice's updated corporate compliance guidance, as there had been following the publication of the original version two years earlier. Many blogs, articles and summaries present the guidance as a road map, a “best practice” guide for an effective compliance program. This view, however, misses the mark. While the guidance can be incredibly useful, using it as a best practice guide overlooks and overstates its true purpose and intent.

As the author of the original document, the 2017 “Evaluation of Corporate Compliance Programs,” and one of the...

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