Davis Polk partner Dan Kahn was featured in a Q&A in Anti-Corruption Report, discussing his career at the DOJ and how the department’s views of corporate compliance programs has evolved over time. Dan explained that when he began working at the DOJ, “there was some understanding of compliance because it has always been a part of the Principles of Prosecution of Business Organizations. Compliance was always something that would be asked about when determining whether a company should get credit in connection with a resolution, what type of resolution was appropriate and whether a monitor should be imposed. However, the types of questions that were asked by DOJ prosecutors and the presentations that were made by defense counsel when I first started were not very detailed, nuanced or sophisticated.”

“Dan Kahn Reflects on the DOJ’s Compliance Evolution,” Anti-Corruption Report (May 25, 2022) (subscription required)

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