Justice Dept. Updates Compliance Guidance Again


The Justice Department updated its guidance for evaluating effective compliance programs on Monday, adding new material about how often a company reviews the structure of its program, a compliance officer’s access to data, and how companies integrate acquisitions into their existing programs.  The department posted the update without fanfare on Monday afternoon, and had made…

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Future of the ‘Effectiveness Questions’

The other day a compliance officer asked me an interesting question: What’s going to happen to the Justice Department’s guidelines for evaluating the effectiveness of compliance programs? After all, the Trump Administration talks all the time about streamlining regulation. Deputy attorney general Rod Rosenstein has given a series of speeches this fall promising reviews of…

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