The U.S. Department of Justice (DOJ) is serious about reforming its corporate enforcement policies and is well-positioned to continue its recent False Claims Act (FCA) reform efforts by focusing on credits for companies that implement effective compliance and ethics programs. Many companies already have such programs, but if DOJ formalizes a policy to offer credit, it will provide a significant incentive to companies that haven’t yet taken that step. This paper addresses how DOJ can help companies make the business case for implementing effective compliance and ethics programs, enabling them to create and sustain a culture of compliance that prevents, detects, and mitigates wrongdoing on the front end.

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