11
Nov
Whether a company’s compliance program works in practice is one of the three fundamental questions prosecutors ask when evaluating corporate compliance programs. Effective implementation is a key metric for the overall effectiveness of the program. Companies may be wondering the same thing about recently updated compliance guidance from the Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”): how does it work in practice? In other words, how have regulators applied the guidance in recent enforcement actions?
This summer, the DOJ...