The ECCP is intended to assist federal prosecutors in determining whether a corporation’s compliance program was effective at the time of the alleged offense(s) and, if not, what type of enforcement, monetary penalty, and...more
On March 3, 2023, the Criminal Division of the U.S. Department of Justice ("DOJ") revised its Evaluation of Corporate Compliance Programs or ECCP (the “March 2023 ECCP”) for the first time since June 2020....more
Recent scrutiny of interlocking directorates – when a person serves as an officer or board director of two competing corporations – by the U.S. Department of Justice Antitrust Division (DOJ) and the Federal Trade Commission...more
On September 28, 2022, the Assistant Attorney General for the Criminal Division of the United States Department of Justice (DOJ) joined the Inspector General for the United States Department of Health and Human Services...more
Speaking at a Compliance Week event on May 17, 2022, Assistant Attorney General (“AAG”) Kenneth Polite reaffirmed that companies that “take compliance seriously” can expect a reduced likelihood that investigators will impose...more