A PR Blitz as DOJ Fine-Tunes Its Corporate Enforcement Policies

In a recent speech, Deputy Attorney General Lisa Monaco announced that the DOJ, “with a combination of carrots and sticks,” is “giving general counsels and chief compliance officers the tools they need to make a business case for responsible corporate behavior.” That same day, the DOJ released a memorandum from Monaco further revising corporate criminal enforcement policies. In the Department’s sights are individual accountability, repeat offenders and compensation packages. Also on the DOJ’s to-do list: promoting self-disclosure and fostering greater transparency and equity in choosing compliance monitors. The Department will be doing this while bolstering internal consistency within its own ranks. A more predictable DOJ may also be a more flush one. In her speech, Monaco mentioned “the $250 million we are requesting from Congress for corporate crime initiatives next year.” This is the first of the Cybersecurity Law Report’s series on Monaco’s speech, the latest iteration of corporate criminal enforcement policies and what they mean for the defense bar and impacted organizations. See “Implications of DOJ’s Pursuit of the Crypto-Laundering Couple” (Mar. 23, 2022).

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