by Leslie R. Caldwell, Douglas K. Yatter, and E. Wistar Wilson

On October 6, 2017, Deputy Attorney General of the United States Rod J. Rosenstein announced that the Department of Justice (DOJ) is actively reviewing a wide range of existing corporate enforcement policies. In a speech delivered at New York University School of Law’s Program on Corporate Compliance and Enforcement, Rosenstein unveiled a plan to review and reconsider existing DOJ policies, and to consolidate policies in official sources like the US Attorneys’ Manual, which provides formal guidance to all DOJ prosecutors.[1] This represents a departure from DOJ’s approach in recent years, and may result in significant changes to DOJ policy in a number of areas. This article summarizes Rosenstein’s remarks, notes related DOJ developments, and discusses possible implications for corporate enforcement. Continue reading →