Using the DOJ’s Compliance Evaluation as an Anti-Fraud Tool

As businesses navigate their way through the new normal after a tumultuous 18 months, it is imperative that they remember to fine-tune the anti-fraud tools already stocked in their corporate arsenal. In this guest article, Nicholas Lynn, a partner at Duane Morris, and Howard Stone, a partner at Stone McGuire & Siegel, explain how anti-fraud and anti-corruption enforcement is increasing, and how to use not only the DOJ’s Evaluation of Corporate Compliance Programs but also parts of the IRS Manual and the FBI Manuals to enhance the efficacy of a company’s compliance program and to better protect the company (and employees) against a criminal investigation and/or indictment. See “Revisiting Compliance Programs in Light of the DOJ’s Updated ECCP” (Sep. 30, 2020).

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