What You Need To Know on New DOJ Corporate Enforcement Policies and Changes To Come
In a clear effort to motivate company cooperation in the reduction of corporate crime, the DOJ is turning to companies now more than ever to come forward by promoting transparency and predictability in how decisions regarding cooperation will be made and the factors that will be considered.
September 28, 2022 at 02:03 PM
7 minute read
On Sept. 15, 2022, Deputy Attorney General Lisa Monaco of the U.S. Department of Justice (DOJ) issued a Memorandum supplementing prior DOJ guidance on corporate criminal enforcement policies, titled Further Revisions to Corporate Criminal Enforcement Policies Following Discussions with Corporate Crime Advisory Group (the Memorandum). The Memorandum came the same day Deputy AG Monaco delivered remarks on the subject and three days after Glenn Leon, the former chief compliance executive at Hewlett Packard Enterprise, started as the new chief of the DOJ Criminal Division's Fraud Section, which investigates and prosecutes health care fraud, financial fraud, and violations of the Foreign Corrupt Practices Act (FCPA), among other corporate crimes. Chief Leon has been lauded as well-situated to balance DOJ's enforcement practices with his understanding of the practicalities of running a business. With this new guidance in place and new leadership at the helm, we appear to be entering a new era of corporate crime enforcement.
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