Assessing an Ethics and Compliance Program

摘要

The Department of Justice on Feb. 8 released guidance entitled, "Evaluation of Corporate Compliance Programs," which provides insight into how it evaluates the effectiveness of corporate compliance programs as the result of an investigation. Although the department is reluctant to be precise about how it conducts evaluations, the recent guidance does provide a list of common topics and questions to expect if programs ever come under that level of scrutiny.