Joseph Ptomey – Debevoise Data Blog

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DOJ Issues Trio of Updates that Further Heighten Compliance Expectations, Particularly Involving Off-System Communications and Compensation Systems

By: Kara Brockmeyer, Andrew M. Levine, David A. O'Neil, Kristin Snyder, Bruce Yannett, Charu A. Chandrasekhar, Andreas A. Glimenakis and Joseph Ptomey March 6, 2023

On March 2 and 3, 2023, the U.S. Department of Justice (“DOJ”) announced several updates to its corporate enforcement policies, in significant part formalizing recent pronouncements about corporate compliance programs.…