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ARTICLE · 05 OCTOBER 2022

DOJ Announces Reforms To Corporate Criminal Enforcement

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On September 15th and 16th, Deputy Attorney General Lisa Monaco and Assistant Attorney General Kenneth Polite delivered remarks on corporate misconduct and compliance programs.

United StatesCompliance

On September 15th and 16th, Deputy Attorney General Lisa Monaco ("DAG Monaco") and Assistant Attorney General Kenneth Polite ("AAG Polite") delivered remarks on corporate misconduct and compliance programs. These remarks contain important conclusions regarding the Department's focus on the prosecution of individuals in corporate cases, credit for corporate self-disclosure and cooperation, evaluation of existing compliance programs in making charging decisions, and the use of monitors. Their remarks also raised questions about limits on the use of NPA/DPAs, CCO certifications in corporate settlements, as well as areas of focus for upcoming guidance.

Three Takeaways from These Remarks for GCs and CCOs:

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