Client Alert

Criminal division of the US Department of Justice announces update to the guidance on the effectiveness of compliance programs

May 9, 2019

In the last week of April 2019, the US Department of Justice published an update in the Guidance on the Effectiveness of the Corporate Compliance Programs. It is crystal clear that the effectiveness of compliance programs has generally been a factor in reducing penalties in anti-corruption laws around the world.

The update by the US Department of Justice increased the 8-page document to 18 pages, and in fact, it was a joint effort including attorneys from the Office of the Assistant Attorney General, Fraud Section, and the Money Laundering and Asset Recovery Section. The new contents addresses 3 issues:

1 – Is it well designed?

2 – Is it effectively implemented?

3 – Does it work in practice?

It has brought important considerations in structuring compliance programs, especially for the purpose of helping companies meet what the US Department of Justice expects them to do.

If you wish to read this document, please click here.

Licks Attorneys is ready to support you and provide any assessment to measure how strong is your compliance program, implementing all additional actions to make it solid. You are encouraged to contact our Compliance Group Practice through our partner – Alex Dalmasso by e-mail: or phone: +55 11 99223 4489.

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