DOJ Policies on Corporate Compliance Programs

Either as a matter of internal policy or in response to specific requirements included in legislative actions, many government agencies have issued rules and guidelines relating to corporate compliance programs.  This report provides an overview of the latest influential statement of policy issued by the Department of Justice regarding the factors that federal prosecutors should consider in deciding whether to pursue criminal charges against a corporate target.  Among other things, the policy–referred to as the Filip Memorandum–discusses how prosecutors should evaluate the effectiveness of a compliance program.

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