DOJ Issues Updated Guidance on the Evaluation of Corporate Compliance Programs

On April 30, 2019, the Criminal Division of the U.S. Department of Justice released updated guidance to its attorneys on how to evaluate the design, implementation and effective operation of corporate compliance programs in determining whether, and to what extent, the DOJ considers a corporation’s compliance program to have been effective at the time of the offense and to be effective at the time of a charging decision or resolution. The DOJ guidance is available here, and the Sullivan & Cromwell memorandum on the topic is available here.