The Department of Justice recently published an updated version of the Criminal Division’s 2017 guidance publication “Evaluation of Corporate Compliance Programs.” The update is intended to harmonize the former Fraud Section publication with other Department legal standards. The updated guidance primarily focuses on three sections:
1. Is the corporation’s compliance program well designed?
2. Is the program being applied earnestly and in good faith?
3. Does the corporation’s compliance program work in practice?
The publication provides additional support in answering the three questions: