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Justice Department issues new guidance on corporate compliance programs

Ty E. Howard (thoward@bradley.com) is a Partner and Elise K. Reecer (ereecer@bradley.com) is an Associate in the Nashville offices of Bradley Arant Boult Cummings LLP.

On April 30, 2019, Assistant Attorney General (AAG) Brian A. Benczkowski issued an updated version of the Department of Justice’s (DOJ) guidance document “Evaluation of Corporate Compliance Programs,”[1] which is intended to assist prosecutors in evaluating corporate compliance programs and guide corporations in creating them. The new guidance rewrites a prior version issued in February 2017[2] and consolidates several DOJ sources used to evaluate compliance programs. DOJ’s stated goal in this recent update is to “better harmonize the guidance with other Department guidance and standards while providing additional context to the multifactor analysis of a company’s compliance program.”[3]

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