Editor’s Note: On September 15, 2022, the Program on Corporate Compliance and Enforcement (PCCE) at New York University School of Law hosted Deputy Attorney General Lisa O. Monaco while she delivered a speech detailing significant changes to the Department of Justice’s corporate prosecution policies. The speech and accompanying policy memo are available here. Over the coming days and weeks, PCCE will be publishing reactions to the new DOJ policies by practitioners, scholars, and compliance officers.
The Department of Justice’s (DOJ’s) September 15, 2022, Memorandum on Further Revisions to Corporate Criminal Enforcement Policies (DOJ Policy), announced by Deputy Attorney General (DAG) Lisa Monaco at an event hosted by the Program on Corporate Compliance and Enforcement at NYU Law, contains several new and significant announcements and revisions to DOJ policy. The defense bar and in-house lawyers involved in ongoing investigations are closely studying these revisions to DOJ prosecutorial standards for individual accountability, prior misconduct, evaluating a corporation’s self-reporting, timely disclosure of evidence, and increased scrutiny to monitorship decisions and oversight.