Skip to main content

On June 1, 2020, the Criminal Division of the U.S. Department of Justice (DOJ) issued an updated version of its “Evaluation of Corporate Compliance Program” guidance. This is another reminder of the DOJ’s heightened focus regarding evaluating compliance programs during investigations and CBP’s internal control focus during audits. When was the last time you had an evaluation of the adequacy of your internal controls?  Do you know the difference between tests of control vs. tests of compliance?