Evaluating Corporate Compliance—DOJ Guidelines for Prosecutors

Posted by Jeffrey Lehtman, Roxana Mondragon-Motta, and Seth Cowell, Wilson Sonsini Goodrich & Rosati, on Sunday, May 19, 2019 Editor's Note: Jeffrey Lehtman is partner and Roxana Mondragon-Motta and Seth Cowell are associates at Wilson Sonsini Goodrich & Rosati. This post is based on their WSGR memorandum. On April 30, 2019, Assistant Attorney General Brian A. Benczkowski announced the release of an updated version of the Criminal Division’s The Evaluation of Corporate Compliance Programs during a keynote address at the Ethics and Compliance Initiative 2019 Annual Impact Conference. This publication, which provides guidance to the Department of Justice’s (DOJ’s) white-collar prosecutors on their evaluation of corporate compliance programs, is an update to an earlier memorandum issued by the Fraud Section in 2017 and, according to the DOJ, is intended to align the guidance with other DOJ guidance and standards on point. The guidance is…

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