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 4 discussed specific examples, and ways to address risks proactively, including: COVID-19’s impact on pharmaceutical industry’s large payments to certain third parties; How costs associated with virtual events may be a red flag; Practical tips on building a proactive data-driven compliance program designed to catch these problem areas before the data is made public.
Click here to view a recording of this webinar.