international regulatory enforcement
“Lessons Learned” by DOJ Provide Further Guidance on Developing a Dynamic Compliance Program
By The Investigations and White Collar Defense Practice Group
The U.S. Department of Justice (“DOJ”) latest guidance demonstrates that DOJ is listening to its own advice—making adjustments to its own guidance documents based on what its prosecutors have learned from investigations, compliance presentations, and monitorships during the past year. DOJ’s (now periodic) updates to the Evaluation of Corporate Compliance Programs guidelines sets forth some important modifications.