![]() ![]() This priority is of course not new, and dates back at least a decade. The DAG reiterated that DOJ’s number one priority is individual accountability, and emphasized its intention to prosecute individuals who commit and profit from corporate crime. Individual accountability and speed of investigations ![]() ![]() Nonetheless, there are several key aspects that clients should review closely and we will continue to monitor whether these changes will be a significant “game changer.” 1. These varying perspectives appear to have impacted the new guidance and approach by the DAG, which continued to strike an exacting tone but, unlike her speech in October 2021, included some carrots in addition to the sticks.Īlthough the speech and memorandum include specific details, the ultimate impact of the new guidance is not yet clear, including because the guidance still leaves prosecutors considerable discretion and because additional guidance is yet to come. In crafting the new guidance, the DAG noted that the Department collected a broad range of perspectives from outside experts, including public interest groups, ethicists, academics, audit committee members, in-house attorneys, former corporate monitors, and members of the business community and defense bar, and incorporated the insights collected. During a speech and in an accompanying memorandum, the Deputy Attorney General reiterated DOJ’s commitment to corporate criminal enforcement-including through a request to Congress for $250 million for corporate criminal enforcement initiatives-and addressed topics such as individual accountability, corporate cooperation, recidivism, voluntary self-disclosures, independent compliance monitors, off-systems communications and the promotion of compliance through financial incentives, including compensation clawbacks. On Thursday, September 15, 2022, Deputy Attorney General Lisa Monaco made good on her pledge to provide additional guidance around DOJ’s corporate criminal enforcement. ![]()
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