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ARTICLE · 04 OCTOBER 2022

FCPA Update September 2022

Debevoise & Plimpton
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In a coordinated set of speeches this month, Deputy Attorney General Lisa Monaco and two of her top staff – Principal Associate DAG Marshall Miller and Criminal Division head Kenneth Polite...

United StatesCorporate/Commercial Law
Kara Brockmeyer
Kara Brockmeyer
Andrew M. Levine
Andrew M. Levine
Winston M. Paes
Winston M. Paes
Jane Shvets
Jane Shvets
Bruce E. Yannett
Bruce E. Yannett
Philip Rohlik
Philip Rohlik
Samuel E. Gelb
Samuel E. Gelb
Andreas A. Glimenakis
Andreas A. Glimenakis
Lorena Rodriguez
Lorena Rodriguez

Biden Administration Doubles Down on Corporate Criminal Enforcement

In a coordinated set of speeches this month, Deputy Attorney General Lisa Monaco and two of her top staff - Principal Associate DAG Marshall Miller and Criminal Division head Kenneth Polite - provided new guidance for companies and individuals facing criminal investigations.1 In particular, the speeches, and an accompanying memo released on September 15 (the "Monaco Memo"), reiterated DOJ's prioritization of individual accountability, provided additional helpful guidance on how DOJ views recidivism, self-disclosure, and monitors, and discussed the importance of compensation clawbacks and policies related to personal devices.

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