Corporate Compliance as a Matter of National Security: DOJ ‘Surging’ Criminal Enforcement Resources
The DOJ has taken several steps in recent years to sharpen its focus on corporate crime. And while enforcement numbers ...
Tag: Monaco Memo
Appointed by President Joe Biden, Deputy Attorney General Lisa Monaco issued a series of policy clarifications aimed at strengthening the DOJ’s fight against corporate crime. In a pair of memos (the first in October 2021 and the second in September 2022), Monaco addressed areas like individual accountability, prior misconduct, cooperation credit, business communications, voluntary self-disclosure, compliance program assessment and monitors.
These memos follow the path of the so-called Yates memo, which represented major white-collar enforcement policy changes during the Obama years. Corporations and their compliance teams should closely monitor further announcement of enforcement priorities by the DOJ.
The articles below cover many aspects of the DOJ’s approach under Monaco regarding corporate criminal enforcement and how companies can best mitigate their risk of drawing undue government attention.
Monaco Memo 2.0: Companies Should Start Preparing Now for Future DOJ Investigations
Use of third-party apps, executive compensation need attention sooner rather than later
DOJ Signals Expanded Use of Independent Monitors for Corporate Criminal Enforcement
The DOJ indicates that it will increase the use of monitors in corporate criminal enforcement; what does that mean for ...
Top CCO Resolution for 2023: Use DOJ’s Guidance to Chart a Path Around Danger
The feds are cracking down, but they’ve also given us a cheat sheet
With Great ‘Empowerment’ Comes Great Responsibility (and Risk) for CCOs Under Monaco Memo
Despite recent statement by DOJ official, CCO certification could hang like Sword of Damocles
4 Practical Tips for Complying With Monaco Memo
Corporate counsel’s obligations are heavy, but swift and complete cooperation are key
Slicing Up DOJ’s Half-a-Loaf Update to Corporate Enforcement Policy
The DOJ's updated corporate enforcement policy continues to push companies to self-disclose potential criminal issues "at the earliest possible time" ...
Fraud Section’s 2022: A Year of Individual Accountability, Cooperation With Foreign Authorities & Pushing Compliance Programs
Unpacking 12 months of DOJ Fraud Section cases: 342 individuals convicted
Our Shared Neighborhood: Corporate Criminal Enforcement & Compliance in Latin America
Navigating pitfalls of doing business in risk-filled region
Eurovision on Anti-Corruption Programs: Everyone Singing From the Same Songbook?
EU proposal is likely to have European nations, US harmonizing on fight against fraud
