Paul Weiss Discusses New DOJ Guidance For Evaluating Corporate Compliance Programs

The United States Department of Justice’s Fraud Section recently released a guidance document entitled Evaluation of Corporate Compliance Programs (“Evaluation Guidance”),[1] which sets forth a list of common questions that the Fraud Section may ask in evaluating corporate compliance programs in the context of a criminal investigation. The Evaluation Guidance does not provide benchmarks, specific factors or requirements for corporate compliance programs to meet. Rather, it sets forth 119 “common questions that the Fraud Section may ask in making an individualized determination” regarding corporate compliance programs.

Release of the Evaluation Guidance fulfills a promise made a year earlier by … Read more