The U.S. Department of Justice continues to churn out policies and guidance reflecting the view that it is not merely looking to punish companies for their employees’ misdeeds, but to help the companies get better quicker.
Whether viewing the Fraud Section’s recent “Evaluation of Corporate Compliance Programs”1 or the National Security Division’s “Guidance on Voluntary Self-Disclosures,”2 the message is much the same: the Justice Department isn’t just focused on deterrence and accountability, but is becoming more interested in ensuring that companies implement effective compliance programs to prevent and detect future misconduct. While these principles have long been ensconced in Chapter Eight of the U.S. Sentencing Guidelines, the subtle but growing focus on corporate get-well programs fits hand-in-glove with the Yates Memo’s unstated raison d’etre:3 Corporate penalties often fail to hit those who deserve it most.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
LexisNexis® and Bloomberg Law are third party online distributors of the broad collection of current and archived versions of ALM's legal news publications. LexisNexis® and Bloomberg Law customers are able to access and use ALM's content, including content from the National Law Journal, The American Lawyer, Legaltech News, The New York Law Journal, and Corporate Counsel, as well as other sources of legal information.
For questions call 1-877-256-2472 or contact us at [email protected]
