DOJ’s Great Expectations For Companies’ Compliance Programs

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In Great Expectations,  DOJ holds anti-corruption compliance programs to a high standard in evaluating their credibility, our colleagues Bill Sullivan, Nancy Fischer, Aaron Hutman and Fabio Leonardi discuss the U.S. Department of Justice’s (DOJ) February 8 release of a list of important topics and sample questions that the Criminal Division’s Fraud Section has frequently found relevant in evaluating the adequacy of a corporate compliance program. The new guidance is intended to assist ethics and compliance officers in crafting effective corporate compliance policies and procedures, and signals how DOJ’s new compliance expert, Hui Chen, is expected to assess a company’s compliance program.