Tag Archives: Marshall Miller

Continuity and Change at the Intersection of National Security and Corporate Crime

by Marshall L. Miller

Photo of the author

Photo courtesy of the author

Much recent attention has centered on shifts in approach at the Department of Justice in the new Administration, but one area where we should expect as much continuity as change is at the intersection of corporate crime and national security. 

During two separate leadership stints at the Department of Justice, I oversaw corporate criminal enforcement—from 2014 to 2015 and again from 2022 to 2024.  The difference was night and day.  Where national security prosecutions were corporate crime outliers in the mid-2010s, by 2022 they represented a majority of DOJ’s major corporate criminal resolutions.  And then the number doubled from 2022 to 2023. Early signals indicate that national security will be a continued area of white-collar focus in 2025 and beyond.

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Looking Back at Fall 2023 PCCE Events: 3rd Annual Directors’ Academy

As we begin to prepare for a full schedule of events in 2024, starting with an event on Voluntary Self-Disclosure Policy for Export Controls Violations on January 16, 2024, the NYU School of Law Program on Corporate Compliance and Enforcement (PCCE) is taking a moment to reflect on our busy Fall 2023 program. In this post: our third annual PCCE Directors’ Academy on September 21-22, 2023.

Photo of speaker

Keynote speaker Heather Lavallee, CEO, Voya Financial, Inc. (©Hollenshead: Courtesy of NYU Photo Bureau)

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With Lava Jato Closing Up Shop, What Comes Next?

by Sean Hecker, Marshall Miller, and Ana Frischtak

The largest criminal investigation in Brazil’s history – and perhaps this century’s most important anti-corruption investigation worldwide – came to a close last week.  Operation “Lava Jato” (“Car Wash,” in English) was launched by the Curitiba[1] branch of the Brazilian Federal Police in 2014, (later known as the Curitiba Task Force).[2]  The Operation, which drew its name from a car wash in Brasília where one of the targeted criminal organizations laundered illicit funds, uncovered a widespread, complex, and unprecedented web of corruption implicating Brazil’s giant state-owned oil company, Petrobrás, public officials, and Brazil’s largest construction companies in a sweeping contracts-for-kickbacks scheme. Operation Lava Jato ultimately expanded to expose bribery and graft in numerous other industries, involving dozens of politicians and government officials, and an almost countless number of companies, both Brazilian and multinational.

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