Jeffrey M. Kaplan (jkaplan@kaplanwalker.com) is a Partner with Kaplan & Walker LLP in Princeton, New Jersey, USA.
On April 30, 2019, Assistant Attorney General Brian Benczkowski announced the publication of an updated version of the Evaluation of Corporate Compliance Programs (the new guidance), superseding an evaluation criteria document published in 2017 by the Department of Justice (DOJ). Although the new guidance[1] does not materially alter the DOJ’s criteria for evaluating compliance program efficacy, its issuance is an important development that compliance and ethics (C&E) professionals should be aware of. The new guidance constitutes the most comprehensive set of standards ever promulgated by DOJ in this area. As such, it should also be used by companies for C&E internal and external self-assessments.