DOJ Raises the Bar on Corporate Ethics and Compliance Programs (April 2023)

The Justice Department continues to increase its expectations for corporate ethics and compliance programs. In recent months, DOJ has issued revisions to its Corporate Enforcement Policy and Evaluation of Corporate Compliance Programs. DOJ ‘s Criminal Division issued new guidance governing its Pilot Program governing Corporate Compliance Compensation Systems and Clawbacks. In combination, these documents underscore significant changes in DOJ’s expectations with respect to corporate compliance programs.
In addition, DOJ and the Office of Foreign Asset Control (“OFAC”) and the Department of Commerce’s Bureau of Industry and Security released a Joint Notice on compliance with the Russia Sanctions Program. This Joint Notice provides important guidance on a number of compliance issues and evasion risks relating to the Russia Sanctions Program.
In this webinar, Michael Volkov will review these important developments and provide practical advice on how to meet these new requirements and compliance program expectations.

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