Davis Polk partner Dan Kahn was featured on Compliance Perspectives, a podcast hosted by Adam Turteltaub, chief engagement and strategy officer at the Society of Corporate Compliance and Ethics (SCCE). In the episode, Dan provides an overview of the latest changes in DOJ enforcement policies and how companies should prepare for the upcoming change in administration.

Dan noted that there were a number of meaningful changes over the last few years. Most notably, the voluntary disclosure program was significantly expanded – a company may still receive a declination even if aggravating circumstances are present. The organization must have disclosed promptly, engaged in extraordinary cooperation and remediation, and have had an effective compliance program at the time of the incident.

Dan added that companies should “stay the course” when it comes to prioritizing compliance, regardless of the change in administration.

“Dan Kahn on the Latest Changes from the DOJ,” Compliance Perspectives (January 9, 2025)

Copy link to share post