Earlier this month, DOJ updated its Corporate Enforcement Policy (CEP). Aimed at encouraging companies to voluntarily disclose unlawful conduct, the updated CEP gives greater opportunities to companies to avoid charges altogether or to get more cooperation credit.
On January 17, 2023, DOJ announced what Assistant Attorney General Kenneth
The U.S. Department of Justice is eyeing new guidance for how prosecutors should assess employee compensation packages when determining whether a company’s compliance efforts warrant favorable treatment in the resolution of criminal investigations.
Acting Principal Deputy Assistant Attorney General Nicole Argentieri said Thursday that the Criminal Division is considering new guidance that would help companies
On September 15, Deputy Attorney General Lisa Monaco announced revisions to the Department of Justice’s corporate criminal enforcement policies. In her speech at New York University and subsequent memorandum (the “Monaco Memo”), Monaco outlined this updated guidance, which focused on individual accountability, prior misconduct, voluntary self-disclosures, monitorships, and compensation structures that promote compliance.