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Fraud Section Guidance Highlights Factors Considered in Evaluating Corporate Compliance Programs

March 2, 2017, Covington Alert

The Fraud Section of the U.S. Department of Justice (“DOJ”) quietly released new guidance last month entitled “Evaluation of Corporate Compliance Programs” (the “Guidance”). While noting that “the Fraud Section does not use any rigid formula to assess the effectiveness of corporate compliance programs,” the eight-page Guidance outlines 11 “Sample Topics and Questions” that DOJ “has frequently found relevant in evaluating a corporate compliance program” in the context of a criminal investigation.

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