5 minute read | March.07.2023
DOJ is roaring into March with updates to its guidance on the evaluation of corporate compliance programs, a new pilot program on compensation incentives and clawbacks, and a revised policy on monitor selection, all released in the last week. We are tracking and analyzing these updates in real time and will be issuing a series of in-depth analyses.
For now, here are the key takeaways coming out of last week:
Read on for more details about these updates.
DOJ’s “Evaluation of Corporate Compliance Programs” sets forth the criteria prosecutors use to determine whether a company’s compliance program is effective. The most significant of the recent changes fall into two categories: (1) personal device and ephemeral messaging policies and procedures; and (2) incentives and disciplinary measures – which DOJ has rebranded as “Compensation Structures and Consequence Management.”
Want to know more about these changes and their impact? Stay tuned: these topics and more will be explored in greater detail by our team in the coming weeks.