Tag Archives: Enforcement

DOJ’s New Guidelines on Repeat Corporate Misconduct: Do They Have Real Teeth?

On October 28, 2021, Deputy Attorney General Lisa Monaco released a memo setting out “Initial Revisions to Corporate Criminal Enforcement Policies.” The memo indicated that the Department of Justice would place greater emphasis on a corporation’s “history of misconduct” in reaching determinations about whether to criminally charge a corporation. Noting that past misconduct is potentially indicative of the strength of internal controls to prevent criminal activity,… More

DOJ Updates Policies on Corporate Ethics and Compliance

Last week, Deputy Attorney General Lisa O. Monaco delivered remarks on corporate criminal enforcement, announcing revisions to DOJ’s policies for addressing corporate ethics and compliance matters. These changes reflect an increased focus on holding individuals accountable for corporate wrongdoing, guidance on handling corporate recidivism, further transparency regarding the appropriateness and necessity of monitorships; incentives for voluntary self-disclosure of misconduct; and a recognition of compensation related incentives to garner a corporate culture of compliance.… More