On November 2, Assistant Attorney General Leslie R. Caldwell emphasized the importance of robust corporate compliance programs when she spoke at a roundtable of compliance professionals. AAG Caldwell explained that prosecutors consider the strength of a company’s compliance program when deciding whether to bring criminal charges against it, and she provided some guidance about what an effective compliance program looks like. AAG Caldwell noted that compliance programs could be tailored to the risks faced by different businesses, and added that adopting a “narrow, cramped view of compliance—that it requires only adherence to specific regulations”—would inure to the company’s detriment. She described how at least one of the banks involved in DOJ’s recent FX case made a conscious decision not to address risks from the FX business, because neither the SEC nor CFTC regulated the FX business. AAG Caldwell also outlined the role of DOJ’s compliance counsel, who, she explained, would assist prosecutors in assessing the quality of companies’ compliance programs and determining whether remedial actions would be overly burdensome. Finally, AAG Caldwell described some other hallmarks of a sound compliance program, including whether senior management provides visible support for compliance, whether compliance policies are clearly communicated to employees, and whether the institution makes clear to its vendors and other partners that it takes compliance seriously.