In this 5-part podcast series I visit with Eric Feldman, Senior Vice President of AMI. We look at the Department of Justice Evaluation of Corporate Compliance Programs, (the “2019 Guidance”), which was released in April 2019. Over the next five podcasts we will explore what the 2019 Guidance changes are from the Evaluation of Corporate Compliance Program, released in February 2017, the structure and emphasis of the 2019 Guidance and what it means for the compliance practitioner going forward. In this concluding Episode, we bring together our final thoughts through a consideration of the question “What does it all mean for your compliance practice?” While the 2019 Guidance was written by prosecutors for their use for companies which are under a Foreign Corrupt Practices Act (FCPA) investigation, Feldman views it as “treasure trove of opportunity” because of that very reason. The 2019 Guidance provides details into “how prosecutors are going to be thinking and perhaps, more importantly, how they are being directed to think about an organization’s ethics and compliance obligations and, finally, whether companies under investigation are going to receive credit for it at the end of the day.”
Tag: 2019 DOJ Guidance
In this 5-part podcast series I visit with Eric Feldman, Senior Vice President of AMI. We look at the Department of Justice Evaluation of Corporate Compliance Programs, (the “2019 Guidance”), which was released in April 2019. Over the next five podcasts we will explore what the 2019 Guidance changes are from the Evaluation of Corporate Compliance Program, released in February 2017, the structure and emphasis of the 2019 Guidance and what it means for the compliance practitioner going forward. In Episode 2, we consider the question “Is your program well designed?” We look at risk assessments, policies and procedures, training and communications, Confidential Reporting Structure and Investigative Process, third-party management and mergers and acquisitions.
