New Department of Justice corporate compliance guidance, which updates DOJ’s “Evaluation of Corporate Compliance Programs,” published in April 2019, hammers home the same points: “Companies should adopt a risk-based compliance program, based on a rigorous assessment of the company’s risk profile, embed preventative and detective controls tailored to those particular risks, and be data driven in monitoring the effectiveness of those controls,” according to a paper from three lawyers with Vinson & Elkins. “While the updates are far from a dramatic overhaul, they signal that prosecutors will be looking more closely at whether compliance programs (1) are adequately resourced, (2) have formalized processes in place to continually evaluate their effectiveness, (3) have effectively incorporated the use of data analytics, and (4) adequately address cross-border implications,” they write. Check out the entire paper by V&E partners Ephraim “Fry” Wernick, Michael Ward and associate Lincoln Wesley here.
Published June 28, 2020.
