DOJ Releases Detailed Criteria for Evaluating Compliance Programs
The Department of Justice doubled-down on emphasizing corporate compliance programs with new guidance from the Criminal Division Fraud Section.
The “Evaluation of Corporate Compliance Programs” (Criteria) document was released February 8 without much fanfare, and contains a long list of benchmarks that DOJ says it will use to evaluate the effectiveness of an organization’s compliance program. The Criteria also provides practical guidance on how organizations can evaluate their compliance programs.
Tony Maida works closely with McDermott Will & Emery's health and white-collar teams on criminal, civil and administrative investigations. Mr. Maida also counsels clients on corporate transactions and compliance programs. He has extensive experience in health care fraud and abuse and compliance issues, including the federal Anti-Kickback and Physician Self-Referral/Stark laws, false claims and overpayments, and government investigations.
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