The Department of Justice has updated its internal guidance “Evaluation of Corporate Compliance Programs,” which it uses in determining whether, and to what extent, charges should be brought against a company, as well as how investigations should be resolved. While primarily intended for use in the criminal context, the same guidance could be considered during a civil investigation against a company, such as in a False Claims Act investigation. The document and its updates are excellent resources for a company to use in the company’s ongoing evaluation of its compliance program.
