Analysis of Recent Statements
DOJ Shaping the Future of Corporate Criminal Enforcement
What’s in this whitepaper from Tom Fox:
Along with the recent update to the DOJ’s “Evaluation of Corporate Compliance Programs” document, compliance practitioners can take their cues from two recent speeches by high-ranking DOJ officials, both at the ABA’s 38th annual National Institute on White Collar Crime.
Podcaster and compliance expert Tom Fox digs into the speeches by Deputy Attorney General Lisa Monaco and Assistant Attorney General Kenneth A. Polite Jr. to unearth important insights from the two leaders.
Monaco identified five general areas of DOJ focus when it comes to corporate criminal enforcement, including but not limited to FCPA actions:
- Inspiring a culture of compliance
- Voluntary self-disclosure programs
- Promoting compliance through compensation and clawback programs
- Resource commitments to corporate criminal enforcement
- Individual accountability
Polite spoke mostly about the U.S. commitment to “righteous” prosecution, including those requiring international involvement, such as Glencore, ABB, Danske Bank and Stericycle.
