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Corporate

Mar. 1, 2024

Keeping a watchful eye on the Corporate Compliance Program rule breakers

The Department of Justice expects companies to disclose misconduct within a reasonably prompt time after becoming aware of it, even before completing an internal investigation.

Stephanie Yonekura

Partner, Hogan Lovells US LLC

Phone: (310) 785-4600

Email: stephanie.yonekura@hoganlovells.com

UCLA SOL; Los Angeles CA

Ann Kim

Partner, Hogan Lovells

Alicia M. Matarese

Associate, Hogan Lovells US LLP

Phone: (310) 785-4600

Email: alicia.matarese@hoganlovells.com

Shutterstock

In 2023, the U.S. Department of Justice announced revisions to its Corporate Enforcement Policy and made several revisions to its Evaluation of Corporate Compliance Programs. The revisions were implemented with the goal of encouraging early voluntary self-disclosures, “extraordinary” cooperation, and effective compliance programs. While the intended goal of the policies is clear, the details of how companies will benefit from these revised programs are yet unknown. Th...

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