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It’s been over a year since the Compliance Counsel assumed her role at the Fraud Section of DOJ’s Criminal Division and earlier this year the Fraud Section released additional guidance on how it evaluates compliance programs. The US Sentencing Guidelines allow companies to receive a credit for having a pre-existing compliance program in place even if it failed to prevent misconduct. Even in the absence of a pre-existing compliance program, FCPA settlements show that effective compliance remediation can significantly impact the resolution of an FCPA investigation.
How has the Compliance Counsel impacted this analysis for the DOJ? How has the review of corporate compliance programs changed as a result of the Compliance Counsel’s involvement? Should compliance professionals change the way they view and implement their compliance programs? What should companies do to be in the best position should they have to disclose or defend against potential corruption-related conduct with the DOJ?