This summer, the U.S. Department of Justice announced a mandate to investigate corporate compliance programs, and more acutely, it issued specific instructions to prosecutors to question companies they are investigating on whether those companies’ compliance teams have at their disposal “relevant sources of data to allow for timely and effective monitoring and/or testing of policies, controls, and transactions.”
The DOJ’s guidance also instructed prosecutors to determine whether compliance programs are “adequately resourced and empowered to function effectively.” For good reason, many in the pharmaceutical industry are concerned by this development. But there is good news: The DOJ’s revised guidance gives pharmaceutical companies a blueprint for how to build an effective compliance program.
We are here to help. Porzio's Michael O'Connor and Isha Arora hosted a four-part webinar series designed to help attorneys and compliance professionals in the pharmaceutical industry make sense of this increased scrutiny and to provide the practical guidance and necessary information they may need to prepare for it.
Part 1 focused on helping companies understand who they do business with, ensuring those third parties did the work they were contracted to do, and verifying they were paid fair market value for it. The session also addressed how to think about building data management systems around third-party engagement.
Click here to view a recording of this webinar.