DOJ Paving a More Structured Path for Corporate Criminal Enforcement
The Dorsey Health Law blog team keeps readers up-to-date on relevant topics in the health care industry. In order to do so, the members of the blog team communicate regularly with other practice groups within the firm for applicable updates from client publications. For this post, we would like to thank Dorsey’s RJ Zayed and Katherine Chaves for the following publication:
On September 15, 2022, Deputy Attorney General Lisa Monaco laid out the DOJ’s first substantive changes to white-collar criminal investigations and enforcement under the Biden administration. This comes on the heels of Deputy AG Monaco’s announcement last October to crackdown on corporate wrongdoing. In a speech at NYU law and in a memo distributed across the DOJ, Deputy AG Monaco reemphasized that DOJ’s corporate enforcement policy focuses on individual accountability, corporate responsibility, predictability and transparency, and ways corporate enforcement policies must square with the realities of the modern economy. In an exclusive interview with the New York Times previewing her speech, Deputy AG Monaco stated that, “I wanted very much to arm and empower chief compliance officers and general counsel to be able to go into the boardrooms and say to the C.E.O., to the chair of the board, ‘We need to make these investments in compliance. When I was out of government, I sat on some corporate boards and I saw that those are hard decisions and you have hard trade-off discussions.”
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