5/20/19: By now, most compliance professionals know that DOJ’s Criminal Division recently released Guidance on the factors it would use to determine whether or not to pursue an investigation or enforcement action against a company or individual...
The Evaluation of Corporate Compliance Programs contains a number of familiar considerations but it serves a useful purpose in updating the Division’s thinking about the role of effective compliance in managing possible misconduct. An article posted on Cleary Gottlieb’s Cleary Enforcement Watch focuses specifically on the responsibilities of Directors, providing a useful checklist about what Boards should do in fulfilling their responsibilities for corporate compliance...