When I began, the Department of Justice had recently released its 2012 FCPA Resource Guide, the single best resource for all things FCPA that set the framework for compliance programs going forward with the articulation of the DOJ’s “10 Hallmarks of an Effective Compliance Program.”
In 2015, then-Assistant Attorney General Leslie Caldwell gave further definition to the Justice Department’s views on what constituted a best practices compliance program in remarks at New York University Law School’s Program on Corporate Compliance and Enforcement. In this talk, Caldwell laid out for the first time the key metrics the Justice Department would review to ascertain if a company was actually doing compliance rather than simply having a paper program.
