DOJ Emphasizes Data-Driven Approach to Monitoring and Importance of Culture in Latest Adjustments to Corporate Compliance Program Guidance

K&L Gates analyzes the DOJ's recent update to its compliance program evaluation guidance, noting that it emphasizes (1) the need to adequately resource and empower the compliance function; (2) the importance of data access and data analysis in monitoring program effectiveness; and (3) the need to foster a culture of compliance not only among senior executives but across all levels of employees.