Jeffrey M. Kaplan (jkaplan@kaplanwalker.com) is a Partner with Kaplan & Walker LLP in Princeton, New Jersey, USA.
The Evaluation of Corporate Compliance Programs,[1] updated in June by the Department of Justice (DOJ), is the most significant and evolved set of compliance and ethics program standards ever issued by a US enforcement agenda. While the entire document should be read by compliance and ethics professionals, it is worth paying particular attention to the section on discipline, given the difficulties that this area can pose for companies.