DOJ Issues Trio of Updates that Further Heighten Compliance Expectations, Particularly Involving Off-System Communications and Compensation Systems
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Key takeaways:
- Last week, DOJ announced several updates to its corporate enforcement policies, including revising its Evaluation of Corporate Compliance Programs to include specific guidance on messaging apps and corporate compensation systems. DOJ also launched its first-ever Compensation Incentives and Clawbacks Pilot Program, designed to reward companies for efforts to recoup compensation from culpable employees.
- While many of these updates formalize guidance that has been issued over the last 18 months, the updates provide additional guidance (and expectations) for corporate compliance programs.
- Consistent with recent DOJ memos, these changes reflect DOJ’s continued prioritization of incentivizing companies to help deter criminal conduct in the first place.