In October 2018, the Justice Department released the Benczkowski Memo. Then, in April 2019, the Justice Department released its Evaluation of Corporate Compliance Programs, 2019 Guidance. These documents are properly seen as one continuous statement by the Justice Department on the type of compliance program a company should have in place to detect and prevent a compliance failure, the steps a company should take if it finds itself under DOJ investigation and the factors the DOJ will evaluate to determine if a monitor is required under a FCPA enforcement action.
In this webinar you will learn:
- What are the three ways to think through the structure of your compliance program?
- Why is there a ‘window of opportunity’ for remediation if a company finds itself in a FCPA investigation?
- What is the roadmap to not only avoiding a monitor, but obtaining a Declination?
- What is the DOJ’s emphasis on culture?
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