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Episode 89 -- DOJ Issues New Guidance on Evaluation of Corporate Compliance Programs
On 2 July 2025, the FCA published its long-awaited proposed next steps on addressing non-financial misconduct (NFM) in financial services. In a joint Consultation Paper and Policy Statement (CP25/18), the regulator is...more
In recently released updated guidance, the Antitrust Division (“Antitrust Division”) of the U.S. Department of Justice (“DOJ”) outlined how its prosecutors will assess corporate compliance programs when conducting criminal...more
The guidance stresses heightened focus on emerging antitrust risks, enhanced support and incentives, and proactive monitoring. On November 12, 2024, the Antitrust Division of the US Department of Justice (the Antitrust...more
On September 23, 2024, the Criminal Division of the U.S Department of Justice (“DOJ”) released revised Evaluation of Corporate Compliance Programs guidance (“September 2024 Guidance), last updated in March 2023....more
The U.S. Department of Justice (DOJ) on March 3, 2023, unveiled a new pilot program and announced several important updates to its Evaluation of Corporate Compliance Programs (ECCP) regarding corporate compensation incentives...more
On Friday, March 3, 2023, the Department of Justice (DOJ) Criminal Division released updated guidance regarding the “Evaluation of Corporate Compliance Programs.” Now in its fourth iteration, this guidance replaces the June...more
New Requirements Place Onus on Corporations to Demonstrate more Compliance Capabilities to Receive Consideration from Prosecutors On September 15, 2022, Deputy Attorney General (“DAG”) Lisa Monaco spoke at New York...more
Recently, the Department of Justice (DOJ) updated its “Evaluation of Corporate Compliance Programs” guidance — the third iteration of DOJ’s guidance on this topic. The update is intended to offer transparency as to how DOJ...more
In June, the Department of Justice (DOJ) published an Update to their Evaluation of Corporate Compliance Programs (2020 Update) which set out to provide additional clarity on how enforcement officials will evaluate an...more
On June 1, 2020, the US Department of Justice ("DOJ") published an updated version of its guidance on the "Evaluation of Corporate Compliance Programs" (the "Guidance"), which was first published in February 2017. When...more
The U.S. Department of Justice recently updated its extensive guidance to federal prosecutors across the country regarding how to evaluate corporate compliance programs. This document is a must-read for company leadership,...more
On June 1, the DOJ updated its guidance for evaluating a company’s compliance program when resolving corporate investigations. The updated guidance makes clear that prosecutors should consider a company’s particular...more
Report on Medicare Compliance 29, no. 21 (June 8, 2020) - Whether an organization shows its commitment to compliance with dollars is a new focus of the second update to guidance on evaluating compliance programs from the...more
On Monday, June 2, 2020, the DOJ’s Criminal Division announced updates to its guidance for Evaluation of Corporate Compliance Programs (the “Guidance”). The Guidance is a tool for federal prosecutors to evaluate the...more
The Department of Justice issued additional clarification and revised guidance on June 1, 2020, for corporate program compliance programs. The additional guidance doesn’t introduce substantive changes; however, it emphasizes...more
In a little-noticed move yesterday, the U.S. Department of Justice (“DOJ” or “Department”) quietly amended its most important guidance document on corporate compliance. While the updates are far from a dramatic overhaul, they...more
Over the past several weeks, competing views have emerged from Capitol Hill and the SEC over how the Securities and Exchange Commission (“SEC” or “Commission”) should approach waivers of collateral consequences for parties...more
• The DOJ recently highlighted the benefits of robust corporate compliance programs and its interest in incentivizing such programs as the common thread running throughout its recent enforcement policy changes, including the...more
On April 30, the Criminal Division of the Department of Justice released an update to the Fraud Section’s February 2017 guidance document titled “Evaluation of Corporate Compliance Programs.” ...more
On April 30, 2019, the U.S. Department of Justice (DOJ) released updated guidance detailing how prosecutors will evaluate corporate compliance programs in charging and resolving criminal cases....more
On May 1, 2019, the Criminal Division of the U.S. Department of Justice (DOJ) released updated guidance for prosecutors to utilize in assessing whether an organization had in place “an adequate and effective corporate...more
Last week, the US Department of Justice (DOJ) released its updated guidance on how prosecutors should evaluate corporate compliance programs. The revised guidance reiterates and expands on the hallmarks of successful...more
We are in an exploration of the recently released Evaluation of Corporate Compliance Programs – Guidance Document (2019 Guidance), which was announced (ECI speech) by Assistant Attorney General Brian Benczkowski at the Ethics...more
The DOJ’s recently updated guidance poses helpful questions for UK corporates evaluating the effectiveness of their internal compliance programmes. It is well known that a corporate’s failure to prevent offences can be...more
On April 30, 2019, Assistant Attorney General Brian Benczkowski unveiled an update to the Department of Justice’s Evaluation of Corporate Compliance Programs during a speech in Dallas, Texas.[i] In issuing the new document...more