Fraud Intelligence
US DoJ guidance provides compliance benchmark
John P Cunningham (+ 1 202 835 6148, john.cunningham@bakermckenzie.com) and Crystal Jezierski (+ 1 202 835 6168, crystal.jezierski@bakermckenzie.com) are partners in Baker McKenzie’s compliance and investigations legal practice group in Washington DC. Previously, John served as a federal prosecutor with the DoJ and as an investigative analyst with the Federal Bureau of Investigation. Crystal has held high-level positions at the DoJ and the US House of Representatives Judiciary Committee. Geoff Martin (+ 1 202 835 6136, geoff.martin@bakermckenzie.com), a senior associate, admitted to practise law both in the US State of New York and in England & Wales, also contributed to this article.
Recent guidance issued by the United States’ Department of Justice has contributed helpful articulation of the ground rules
upon which it evaluates the strength of a corporate compliance programme.
John P Cunningham and
Crystal Jezierski of Baker McKenzie outline the key elements.