Has DOJ been sending us the wrong message about compliance programs?  

Has DOJ been sending us the wrong message about compliance programs?  

Why is DOJ so secret about pre-existing compliance programs? Do those programs really count, or is DOJ inadvertently signaling that companies should hold back and wait until something goes wrong? It’s time for DOJ to fix a long-term policy mistake.   

Unfinished Business at the Department of Justice​ – Compliance and Ethics: Ideas & Answers

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