Cleary Gottlieb Discusses DOJ Updates of Guidance on Corporate Compliance Programs

On April 30, 2019, the Criminal Division of the U.S. Department of Justice (“DOJ” or “the Department”) announced updated guidance for the Criminal Division’s Evaluation of Corporate Compliance Programs (“the Guidance”) in charging and resolving criminal cases.[1] Assistant Attorney General Brian A. Benczkowski (“Benczkowski”) made the announcement at the Ethics and Compliance Initiative (ECI) 2019 Annual Impact Conference in Dallas, Texas, noting the DOJ’s effort to “better harmonize the prior Fraud Section publication with other Department guidance and legal standards.”[2]

This memorandum highlights the key updates to the Guidance and discusses the themes present across versions of the … Read more