Client Alert: DOJ Updates Guidance Regarding the “Evaluation of Corporate Compliance Programs” — Key Take-Homes
On Monday, June 1, 2020, the Department of Justice (DOJ) Criminal Division released updated guidance regarding the “Evaluation of Corporate Compliance Programs.” Now in its third iteration, this guidance replaces the April 2019 version, which originated from a set of 2017 guidelines from the Fraud Section. The updated guidance, like prior iterations, seeks to make corporations aware of the criteria DOJ uses when evaluating compliance programs in making enforcement decisions. In the latest version, DOJ maintains the existing structure and much of the prior content, but makes targeted changes.
The new revisions are part of a continuing trend at DOJ to more holistically assess corporate compliance programs beyond the specific issue that brought the company to the Department’s attention, jettisoning the more tailored approach of the original 2017 guidance. In addition, the revisions amplify certain themes in DOJ’s compliance review criteria: (1) whether a company has demonstrable processes to continuously improve its compliance program; (2) the extent to which available data is mined and analyzed to evaluate the company’s compliance efforts; and (3) how compliance is embedded in the day-to-day operations of the business and viewed by rank-and-file employees.
The client alert was recently republished by NYU Law's Program on Corporate Compliance and Enforcement. Please click here to access the blog post.
To read the full alert, please click here.
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© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.
On Monday, June 1, 2020, the Department of Justice (DOJ) Criminal Division released updated guidance regarding the “Evaluation of Corporate Compliance Programs.” Now in its third iteration, this guidance replaces the April 2019 version, which originated from a set of 2017 guidelines from the Fraud Section. The updated guidance, like prior iterations, seeks to make corporations aware of the criteria DOJ uses when evaluating compliance programs in making enforcement decisions. In the latest version, DOJ maintains the existing structure and much of the prior content, but makes targeted changes.
The new revisions are part of a continuing trend at DOJ to more holistically assess corporate compliance programs beyond the specific issue that brought the company to the Department’s attention, jettisoning the more tailored approach of the original 2017 guidance. In addition, the revisions amplify certain themes in DOJ’s compliance review criteria: (1) whether a company has demonstrable processes to continuously improve its compliance program; (2) the extent to which available data is mined and analyzed to evaluate the company’s compliance efforts; and (3) how compliance is embedded in the day-to-day operations of the business and viewed by rank-and-file employees.
The client alert was recently republished by NYU Law's Program on Corporate Compliance and Enforcement. Please click here to access the blog post.
To read the full alert, please click here.
Related Capabilities
Related Locations
© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.
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