DOJ’s Criminal Division updated their Evaluation of Corporate Compliance Programs guidance for FCPA investigations. The new version highlights three key elements for compliance programs:
- Epersonal device and messaging application policies.
- Ecompensation structures for ethical behavior.
- Eenforcement and publicity of internal disciplinary procedures.
Effective risk management is critical in preventing corporate misconduct, and policies regarding personal devices and messaging apps are crucial in today’s digital age. Compensation structures can encourage compliance, and the enforcement and publicity of internal disciplinary procedures demonstrate a company’s commitment to ethical behavior.
The updated guidance underscores the importance of robust compliance programs in preventing and detecting corporate misconduct and reminds businesses to adapt to new areas of concern.
