Critique of the U.S. Department of Justice Evaluation of Corporate Compliance Programs

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Critique of the U.S. Department of Justice Evaluation of Corporate Compliance Programs

Bruce Ortwine, General Counsel, Americas; Adviser, Global Legal and Compliance; Senior Executive Vice President, Sumitomo Mitsui Trust Bank, Limited, USA

On April 30, 2019, the U.S. Department of Justice, Criminal Division (the ’DOJ

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