Post-Enron Expectations: Directors, Investigations and Independence of Process

Assessing Codes of Conduct

Codes of conduct are often described as the most important document in a compliance program. Codes help set the right tone for compliance and ethics (“C&E”) programs. They are educational tools that should serve to raise awareness and understanding of important...

Program Structure

In the posts collected here we will discuss assessment-related issues concerning a) various types of C&E program roles and reporting relationships, including those involving the board of directors; senior management; C&E department management; other staff,...

Revisions to DOJ Program

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...

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 11 of this year when, as...

Conducting Program Assessments Using the Department of Justice’s New Evaluation Standards

The modern era of corporate compliance began on November 1, 1991, when the Federal Sentencing Guidelines for Organizations (the “FSGO”) – the first set of general standards for assessing the efficacy of what were then called “program[s] to prevent and detect...

Post-Enron Expectations: Directors, Investigations and Independence of Process

Recent Post

Assessing Codes of Conduct

Program Structure

Revisions to DOJ Program

The New Antitrust Compliance Program Evaluation Criteria

Conducting Program Assessments Using the Department of Justice’s New Evaluation Standards

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