BC Advantage - 2019 Issue 9

New DOJ Guidance on Evaluating Corporate Compliance Programs

The Department of Justice's (DOJ) Criminal Division recently released a guidance document titled, "The Evaluation of Corporate Compliance Programs," for use with federal prosecutors when investigating corporations for criminal misconduct. This new document updates the 2017 version in order to align with internal processes while providing additional context to the government's analysis of a company's compliance program. Healthcare organizations should take heed and use this guidance to improve its healthcare compliance initiatives. Here we highlight some of the main topics and questions prosecutors will consider in their investigation. This is also relevant when evaluating corporate compliance programs for...

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