Updating Corporate Compliance Programs to Follow New DOJ Guidance
Designing and Implementing Effective Programs Tailored to a Company's Business and Culture
Recording of a 90-minute CLE webinar with Q&A
This CLE webinar will address the DOJ's Apr. 30, 2019 guidance document titled “The Evaluation of Corporate Compliance Programs,” which updates a prior version of the guidance first issued in February 2017. The new guidance provides additional insight into how DOJ will assess a company’s compliance program, including the program’s design, implementation, and effectiveness.
- Program design
- Risk assessment
- Policies and procedures
- Training and communications
- Confidential reporting/investigations
- Third-party management
- Merger and acquisition issues
- Commitment by management
- Autonomy and resources
- Incentives and discipline
- Continuous improvement, testing and review
- Investigation of misconduct
- Analysis and remediation
The panel will review these and other key issues:
- What is the significance of the updated guidance relative to past versions of the guidance?
- What do these DOJ insights reveal about DOJ's investigation priorities going forward?
- How should compliance programs be designed and resourced to reflect an acceptable compliance culture?
- What compliance actions can be taken to protect officers and directors from personal liability?
Michael D. Mann
Mr. Mann is a partner in Sidley’s White Collar: Government Litigation and Investigations practice, where he... | Read More
Mr. Mann is a partner in Sidley’s White Collar: Government Litigation and Investigations practice, where he strategically counsels and defends companies, financial institutions and related individuals in internal, criminal and regulatory investigations, prosecutions and litigations. He is a trusted advisor to senior management and boards of directors faced with some of their most complex and sensitive enforcement and investigation-related issues, including matters concerning alleged bribery and corruption, money laundering, violations of economic sanctions, insider trading, fraud, market manipulation as well as other forms of financial and ethical misconduct.Close
Jennifer Kennedy Park
Cleary Gottlieb Steen & Hamilton
Ms. Park is a partner at Cleary Gottlieb Steen & Hamilton LLP. Her practice focuses on compliance programs,... | Read More
Ms. Park is a partner at Cleary Gottlieb Steen & Hamilton LLP. Her practice focuses on compliance programs, internal investigations and enforcement actions. Jennifer routinely advises global corporations and financial institutions on interactions with regulators and authorities, including regarding remediation programs. Jennifer has regularly interacted with the U.S. banking authorities regarding compliance programs and enhancements. Jennifer has experience dealing with the DOJ, FRB, OCC, CFTC, SEC, DFS, FINRA, OFAC, European Commission, UK FCA, SFO, and other authorities around the world. Recognized as a Rising Star by the New York Law Journal and by NOW as a Woman of Power and Influence, she has handled some of the most complicated matters effecting corporate entities in the last five years.Close