U.S. DOJ new policies on corporate prosecution
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As a result of the Deputy Attorney General’s new policies and directives, we are likely to see:
- Increased effort to bring actions against individuals more quickly.
- A more selective focus on historic misconduct – modifying a 2021 statement, Monaco has limited the focus on older/unrelated misconduct and will contextualise prior violations in more regulated sectors.
- New policies designed to incentivise voluntary self-disclosure.
- Evaluation of corporate compliance programs at the time of the violation (and at the time of negotiating a resolution).
- Increased scrutiny of (1) whether compensation structures incentivise compliance, and (2) policies governing use of personal devices and messaging platforms.
For more information please see our fuller article DOJ announces new policies on corporate prosecution.