Episode three takes a comprehensive look at the state of compliance at the half-year mark of 2019. Terry discusses the recently released Department of Justice (DOJ) 2019 Guidance and what it means for compliance professionals in the U.S.
Terry noted that a prosecutor’s assessment of the adequacy and effectiveness of a compliance program will be critical in determining:
- whether and how to bring a corporate criminal case;
- in determining a company’s culpability score under the U.S. Sentencing Guidelines and
- whether an independent monitor is required post-resolution.
Listen to the podcast to hear Terry’s perspective on the significant differences between the guidance issued in 2017 and the DOJ’s 2019 Guidance.
