The Updated Evaluation of Corporate Compliance Programs Guidance Part 2 – A Well Designed Program

In the second of a series of posts on DOJ's new guidance on corporate compliance programs, Tom Fox considers the first substantive section of the 2019 Guidance: what should go into a well-designed compliance program, or – as it states – “Is the corporation’s compliance program well designed?” He focuses on risk assessments, which should be viewed as an iterative, ongoing process.