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DOJ compliance program guidance and credit for cooperation and self-disclosure

Gabriel L. Imperato (gabriel.imperato@nelsonmullins.com) is the Managing Partner of the Fort Lauderdale office of Nelson Mullins Broad and Cassel and the Team Leader of the firm’s Health Care Criminal and Civil Enforcement, Litigation and Compliance Practice.

The United States Department of Justice (DOJ) recently released documents with guidelines for evaluating corporate compliance programs and cooperation credit and self-disclosure in both criminal and civil enforcement actions. The DOJ Criminal Fraud Section updated its existing guidance entitled Evaluation of Corporate Compliance Programs[1] for its criminal prosecuting attorneys, and the Civil Fraud Branch further elaborated on guidance for cooperation credit and self-disclosure to DOJ attorneys in civil False Claims Act (FCA) cases.[2] These documents emphasize important aspects and best practices for organizational compliance programs and highlight the need for effective corrective action to prevent and detect future occurrences of underlying noncompliant conduct.

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