On 1 June, the Wall Street Journal reported that the revisions resulted in part by feedback from the business and compliance communities.  It is said that the guidance is written as a series of questions that prosecutors can ask companies about their compliance programmes during criminal investigations and serves as an informal set of standards that companies can use when designing compliance programmes.

The guidance is at –

An analysis is also available at –


If you would like to say thanks by making a small contribution, in case I need to upgrade or replace my computers and other paraphernalia, I have a page at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s