DOJ’s Revised Corporate Enforcement Policy Expands on Previous Factors: History of Misconduct; Voluntary Self-Disclosure; and Compliance Monitors (Part III of IV)
The Lisa Monaco Memo is a new and important restatement of the Justice Department’s approach to corporate crime. It is a worthy read and it sets out a number of new requirements and procedures for DOJ prosecutors investigating corporate crime. In this posting, we return to review a few remaining important issues. Evaluating a Corporation’s History of Misconduct — DOJ’s original announcement in October 2021...
