On June 1, 2020, the DOJ updated its Evaluation of Corporate Compliance Programs guidance document to reflect, as Assistant Attorney General Brian Benczkowski said, “additions based on our own experience and important feedback from the business and compliance communities.”
A review of those changes Steele deems substantive is set forth in this white paper. A few key takeaways include:
- The program must be “adequately resourced” and the compliance function must be empowered to “function effectively.”
- The program, once established, must be periodically updated and refined or there is the risk that prosecutors will deem it a “paper” program.
- Compliance policies and procedures should be readily accessible to employees and the company should have the ability to track access to such policies and procedures.
- And many more.
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