Last week, the U.S. Department of Justice (DOJ) updated the guidance that federal prosecutors use to evaluate corporate compliance programs. Update is too strong. Consolidated is a better word. Version 2.0 (should probably be 1.1, but 2.0 sounds better).

Basically, the DOJ took the guidance they issued in 2017 (mostly recycled from long-standing deferred (DPA) and nonprosecution agreements (NPA) and supplemented it with even longer-standing guidance set forth in the U.S. DOJ’s Justice Manual (formerly and more affectionately known as the U.S. Attorneys’ Manual (USAM)), the U.S. Sentencing Guidelines (USSG) and various DOJ policies, such as the FCPA Corporate Enforcement Policy, that have been recently codified into the Justice Manual. It was the regulatory equivalent of Apple releasing a new iPhone with the only new feature being an updated operating system that you could download for free before the update. Yawn.

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