Effective Compliance Programs Look Beyond DOJ Guidance

Law360 (July 30, 2019, 3:54 PM EDT) -- Much ado has been made about the recent guidance on corporate ethics and compliance programs issued by the U.S. Department of Justice. The attention is justified. Starting with the Criminal Division’s evaluation of corporate compliance programs and continuing with the release of the Antitrust Division’s evaluation of corporate compliance programs in criminal antitrust investigations, we now know more about the DOJ’s definition of “effectiveness” when it comes to ethics and compliance than ever before.

Not surprisingly, industry conferences, webcasts and articles are replete with analysis of what it all means for the private sector. This, too, is understandable, as history has...

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