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Abstract: 

Earlier this year, the U.S. Department of Justice (“DOJ”) announced new compliance guidance on compensation structures to incentivize compliance and the use of personal devices and messaging apps to engage in business communications. Although it is still too early to know how these policies will be applied in practice, both guidance announcements provide useful insight into how DOJ is thinking about these issues and how companies may want to modify their compliance programs to achieve the best results if they ever find themselves in front of DOJ or other regulators.

Keywords: Compliance Requirements for Criminal Resolutions; Credits against Fines for Clawbacks

Affiliations:  1: Davis Polk & Wardwell.