On Tuesday, April 30, the Department of Justice (DOJ) Criminal Division released a new document entitled “Evaluation of Corporate Compliance Programs.” The guidance document (the Guidance) replaces a 2017 paper of the same name, but largely reflects a continuity of approach—both in the personnel evaluating compliance programs and the factors they should examine. The 2017 paper provided an informal set of questions to evaluate corporate compliance programs. The Guidance now expands on those same questions, provides greater context to understand the purpose behind the questions and organizes the analysis of compliance programs around three fundamental inquiries.
