Tagged: compliance monitors

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...

Congrats to the New International Association of Independent Corporate Monitors

I was pleased to join a new, and much-needed organization, the International Association of Independent Corporate Monitors (“IAICM” website located here). Congratulations to John Hanson and his colleagues for creating IAICM. John has been active in this area for a long time and is the natural leader of the organization. We all know about the use of corporate monitors in high profile cases involving money...