17 Jul 2019
A recent update to the US Justice Department’s guidance on assessing corporate compliance programmes is intended to help federal prosecutors determine when to pursue criminal indictments or prosecution agreements with companies, but that shouldn’t deter compliance professionals from reviewing the document. There are lessons within for heads of compliance and financial crime teams too.
Most importantly, the guidance can serve as a self-assessment tool for anti-money laundering specialists and others seeking to resolve weaknesses in their firms’ policies and procedures. Such an analysis may help any organisation that transacts with US dollars, given that the DOJ claims criminal jurisdiction over foreign entities that use the world’s strongest currency.
What follows is overview of what the update means for compliance professionals based on three fundamental questions prosecutors are instructed to ask.
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