U.S. Department of Justice’s Compliance Program Evaluation Factors: Impact on Internal Investigation
Practicing Law Institute (PLI) Handbook on Internal Investigations 2017 (pp. 139-143)
John Kocoras wrote this bylined article on a list of common questions issued by the Department of Justice Criminal Division, Fraud Section for evaluating effectiveness of corporate compliance programs. The questions “go beyond routine compliance program management and ... include items that might otherwise be treated as outside the scope of a routine internal investigation,” Mr. Kocoras wrote, urging that compliance officials review them closely.