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New guide of the US Department of Justice – Requirements for a Compliance Management System
This paper was published in comply 3/2019, p. 54ff. comply is the modern trade magazine for compliance officers in companies and organizations.
On April 30, 2019, the U.S. Department of Justice (DOJ) published new guidance on the requirements for compliance management systems, a revised and expanded version of a document of the same name published in February 2017, which collected more than 120 test questions to identify the criteria that DOJ prosecutors should use to assess compliance programs when assessing penalties or entering into a deferred or non-prosecution agreement. This article provides a brief overview.