News from Pohlmann & Company


VCI exchange of experience on Compliance

On March 12, 2020, the German Chemical Industry Association (Verband der Chemischen Industrie, VCI) again hosted its regular internal ‘exchange of experience on Compliance’ in its offices in Frankfurt/Main. Our partner Nicole Willms was invited to present to company representatives the updated guidance document of the US Department of Justice (DoJ) on the Evaluation of Corporate Compliance Programs issued in April 2019. The development towards the new guidance document, important changes compared to the previous version from February 2017 as well as consequences for practice and effects on German companies were explained in detail. There was a fruitful discussion with the participants on the significance and possible role model of the guidance document in the context of the expected German Corporate Sanctions Act (Verbandssanktionengesetz). In this context, it was particularly criticized that no statutory standards or binding guidelines shall be given to companies with regards to the demands and expectations German law enforcement authorities and courts now have and will have in the future towards compliance management systems.

The current version of the DOJ Guidance Document can be found here.

For details on the German Corporate Sanctions Act, status August 2018, please see our previous blog article.