New York partner Peter Baldwin and Philadelphia partner Mary Hansen have authored an article for The National Law Journal titled “Navigating the DOJ’s New Guidance on the Evaluation of Corporate Compliance Programs.” In the article, they review the three “fundamental questions” that federal prosecutors must answer about a company’s corporate compliance program when determining (1) whether criminal charges should be filed; (2) whether and in what amount a fine should be levied; and (3) whether a monitor or some other compliance obligation should be imposed. They further advise that compliance professionals and company management would be wise to pay attention to DOJ’s new guidance, as it provides a helpful roadmap for how DOJ will analyze corporate compliance programs going forward.
Source: The National Law Journal
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