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DOJ review of corporate compliance programs

Ron Miller ( is Of Counsel, Government Services & Finance in the Washington, DC, offices of Barnes & Thornburg LLP.

Corporate compliance programs serve an important purpose in establishing safeguards to protect the corporation and instill a culture of ethical and legal behavior throughout the organization. In the worst case, corporate compliance programs may be evaluated by U.S. Department of Justice (DOJ) attorneys to determine mitigating factors in corporate wrongdoing.

In April 2019, DOJ issued updated guidance for prosecutors[1] to help in evaluating the role of corporate compliance programs and whether those programs should influence prosecution of any offenses. In particular, the guidance focused on three primary questions. First, whether the compliance program was well-designed; second, whether the program was being applied earnestly and in good faith; and third, whether the program worked in practice.

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