On June 1, 2020, the U.S. Department of Justice (“DOJ”), Criminal Division, updated its guidance on the “Evaluation of Corporate Compliance Programs” (“the 2020 Update”) to provide increased clarity on several of the key questions prosecutors might ask in assessing…
Category: Assessment mandates and benefits
In the posts collected here we will identify and discuss the a) principal legal expectations regarding C&E program assessments, including guidance documents issued by enforcement authorities and pertinent case law; and b) various business benefits to conducting assessments, such as providing momentum and direction for a C&E program.
The New Antitrust Compliance Program Evaluation Criteria
For more than a quarter of a century the Antitrust Division of the US Justice Department (the “DOJ”) was an outlier among the components of the DOJ with respect to crediting compliance programs in enforcement matters. That changed on July…
Certification as a form of program evaluation
By Joe Murphy, CCEP A newly evolving approach to program evaluation is certification, particularly to meet an ISO standard. Mostly notably, ISO 37001 provides for certification of anti-corruption compliance programs. There is a great deal of controversy about this certification.…