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ARTICLE · 20 JANUARY 2023

Enforcement Highlights – 2022

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This year, the Department of Justice (DOJ) continued to reaffirm the importance of its June 2020 Evaluation of Corporate Compliance Programs, June 2020 guidance (DOJ Guidance)...

United StatesCriminal Law
Eve Costopoulos
Eve Costopoulos
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I. Refinement of Corporate Criminal Enforcement Principles by Department of Justice

This year, the Department of Justice (DOJ) continued to reaffirm the importance of its June 2020 Evaluation of Corporate Compliance Programs, June 2020 guidance (DOJ Guidance)36 and to further announce important new initiatives that increase the accountability of both corporations and individuals alike. The new initiatives provide corporations and individuals with incentives, such as avoidance of prosecution, reduced fines and penalties, and no imposition of corporate monitor when they take appropriate steps to maintain an effective compliance program.

In March, the Department of Justice (DOJ) Criminal Division announced that, moving forward, the DOJ was considering, whether all corporate criminal settlements, including guilty pleas, deferred prosecution agreement and non-prosecution agreements, should require Chief Executive Officers (CEOs) and Chief Compliance Officers (CCOs) to

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