How Far Will the DOJ Go? Individual Accountability in Corporate Criminal Cases
Why should this concern white-collar professionals? In September 2022, the Deputy Attorney General, Lisa Monaco, reminded prosecutors that individual accountability remains the DOJ's "first priority." And there is time pressure imposed on prosecutors: they must bring these charges before or at the time of resolving the investigation with the company.
January 12, 2023 at 01:49 PM
7 minute read
White Collar CrimeIf you use Whatsapp or similar platforms for work-related communications, then you've probably heard that regulators are putting an end to that practice. Ephemeral and encrypted messaging, they have noted, evades monitoring and prevents retention. If companies can't turn over incriminating communications to law enforcement, then prosecutions against individuals will suffer – an unacceptable outcome to prosecutors bent on making cases against individuals for white collar offenses. And while that's true of felony prosecutions, a seldom used doctrine allows prosecutors to charge executives with misdemeanor offenses just for being in the position of power when others commit the misconduct. Rather than take a wait-and-see approach, companies and their leaders would do well to prepare for prosecutors to reach deep into their toolbox.
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