DOJ Updates Guidance for Evaluating Corporate Compliance Programs as a Record Number of Companies are Receiving Federal Funding

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.