Elkan Abramowitz and Jonathan Sack Recent Guidance Reinforces DOJ Approach to Corporate White-Collar Investigations
In their White-Collar Cirme column, Elkan Abramowitz and Jonathan S. Sack discuss the Criminal Division of the Department of Justice and how it recently issued two important documents that reflect significant continuity in DOJ policy toward corporate white-collar criminal investigations.
September 03, 2020 at 01:11 PM
10 minute read
In this unsettled time, the Criminal Division of the Department of Justice recently issued two important documents that reflect significant continuity in DOJ policy toward corporate white-collar criminal investigations. In June, the Criminal Division issued guidance titled "Evaluation of Corporate Compliance Programs" (Compliance Guidance), which builds on earlier policy statements and instructs prosecutors how to analyze an organization's compliance programs. In July, the Criminal Division together with the Securities and Exchange Commission's Enforcement Division issued the second edition of the "Resource Guide to the US Foreign Corrupt Practices Act" (FCPA Resource Guide), which incorporates policies and rulings issued since release of the original FCPA Resource Guide in 2012.
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