The Thompson Memorandum Provides Compliance Incentives

"The Thompson Memorandum sets forth nine factors for United States Attorneys to consider in deciding whether to investigate, charge, or negotiate a plea with an organization. Three of these factors relate to an effective corporate compliance program:

4. the corporation's timely and voluntary disclosure of wrongdoing and its willingness to cooperate in the investigation of its agents, including, if necessary, the waiver of corporate attorney-client and work product protection;

5. the existence and adequacy of the corporation's compliance program;

6. the corporation's remedial actions, including any efforts to implement an effective corporate compliance program or to improve an existing one, to replace responsible management, to discipline or terminate wrongdoers, to pay restitution, and to cooperate with the relevant government agencies . ."

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