DOJ Guidance for Corporate Compliance Programs: Questions Counsel Should Expect in a Government Investigation

Recording of a 90-minute CLE webinar with Q&A

Conducted on Wednesday, February 21, 2018

Recorded event now available

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Program Materials

This CLE webinar will provide a detailed analysis of the “Evaluation of Corporate Compliance Programs” report (the Report) published in 2017 by the DOJ as well as other more recent DOJ policy changes, such as the FCPA Corporate Enforcement Policy (the FCPA Policy), which was added to the US Attorney’s Manual in November, 2017. The panel will prepare corporate counsel to design and implement a compliance program that will address recent DOJ enforcement priorities and protect its officers and directors from risks and liabilities, including prosecution, in the event of a government investigation.


The DOJ published pointed and specific guidance in 2017 on how it assesses—and intends to assess—compliance programs in the Report. The Report provides insight into the questions corporate counsel should expect from DOJ prosecutors during a criminal investigation and highlights common indicators that DOJ deems a strong corporate culture of compliance.

The Report identifies 11 broad topic areas, along with numerous subtopics and questions that prosecutors may ask when evaluating a compliance program. The Report and subsequent pronouncements, including the FCPA Policy, reflects DOJ’s continued interest in corporate self-reporting, individual responsibility and prioritizing individual accountability in corporate investigations. The Report and FCPA Policy further evidences DOJ’s interest in pursuing individuals in cases of corporate wrongdoing.

The Report and FCPA Policy also set forth a detailed framework of DOJ’s corporate culture expectations. Counsel must lay the groundwork for corporate officers to provide satisfactory answers to DOJ’s questions regarding corporate culture (or explain why they may not apply).

Listen as our authoritative panel provides a detailed analysis of these DOJ materials and their significance in tying together and expanding on enforcement guidance previously released by DOJ. The panel will also discuss the aspects of a robust compliance program that can reflect a strong corporate culture, which helps protect officers and directors from individual prosecution.



  1. DOJ investigations generally—previous areas of focus
  2. Analysis of the Report and the FCPA Policy
  3. Designing a robust compliance program in light of DOJ enforcement priorities
    1. Individual accountability
    2. Corporate culture


The panel will review these and other key issues:

  • What is the significance of the Report and the FCPA Policy relative to previous guidance?
  • What do these DOJ materials reveal about DOJ’s investigation priorities going forward?
  • How should compliance programs be designed to reflect an acceptable compliance culture?
  • What compliance actions can be taken to protect officers and directors from personal liability?


Bezanson, Phil
Phil Bezanson

Managing Partner

Mr. Bezanson represents corporate clients, senior management and boards of directors as well as individual clients in...  |  Read More

Collins, Kevin
Kevin D. Collins


Mr. Collins is a former Assistant U.S. Attorney from the Eastern District of Texas, and he has focused on process...  |  Read More

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