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Compliance Into the Weeds

Update to the Corporate Enforcement Policy

The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more. In this episode, Matt and I deep dive into the recent Kenneth Polite speech announcing changes to the Corporate Enforcement Policy.

Some of the highlights include:

·      What are the policy reasons for the change?

·      Real credit is now being given for effective compliance programs.

·      What about self-disclosure?

·      What is the new definition of an effective compliance program?

·      Is the DOJ trying to avoid 5th Amendment concerns? Will it work?

·      New percentage discounts and what they mean?

·      Why does Matt have more questions?

 Resources

Tom cited in CCI

Matt Kelly in Radical Compliance