Magazine Article | September 8, 2017

What To Know If (Or When) The DOJ Evaluates Your Compliance Program

Source: Life Science Leader

By Cynthia Schnedar, executive VP of regulatory compliance, Greenleaf Health

The United States Attorneys’ Manual is an online document prepared by the U.S. DoJ to be used as a “quick and ready reference” by DoJ prosecutors. Thus, corporations generally do not become too familiar with the majority of the manual.

However, the manual has long contained a provision that should be of interest to all corporations. This particular section, entitled “The Principles of Federal Prosecution of Business Organizations,” describes factors prosecutors “should consider in conducting an investigation of a corporate entity, determining whether to bring charges, and negotiating plea or other agreements.” The principles described in this part are known as the “Filip Factors” because they were revised and expanded in 2008 under the leadership of then-Deputy Attorney General Mark Filip.