U.S. Department of Justice (Criminal Division, Fraud Section) – Guidance on the Evaluation of Corporate Compliance Programs

The Principles of Federal Prosecution of Business Organizations in the United States Attorney’s Manual describe specific factors that prosecutors should consider in conducting an investigation of a corporate entity, determining whether to bring charges, and negotiating plea or other agreements. These factors, commonly known as the “Filip Factors,” include “the existence and effectiveness of the corporation’s pre-existing compliance program” and the corporation’s remedial efforts “to implement an effective corporate compliance program or to improve an existing one…click here to view pdf

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