Menu5/6/19: During his keynote address at the Ethics and Compliance Initiative’s 2019 Annual Impact Conference, Assistant Attorney General Brian A. Benczkowski offered a look at DOJ’s thinking on a number of fronts. Most significant for compliance pros was the announced release of the Criminal Division’s updated Evaluation of Corporate Compliance Programs...
Mr. Benczkowski noted, “In drafting the updated version of the document, we have sought to provide additional transparency in how we will analyze a company’s compliance program.” He goes on to highlight three fundamental questions a prosecutor should ask: is the program well-designed; is the program effectively implemented; and does the program work in practice?
