![]() ![]() Lastly, Assistant Attorney General Kenneth Polite announced planned revisions to DOJ’s Evaluation of Corporate Compliance Programs (ECCP) relating to the treatment of personal devices and ephemeral messaging services used by corporate employees, as well as clawbacks and compensation.ĭOJ is implementing a pilot program to encourage corporations to try to claw back compensation paid to individuals implicated in criminal wrongdoing. Attorney’s Offices with respect to voluntary disclosure by corporations. This follows a recent policy memorandum by the DAG in February 2023 sent to all 93 U.S. David Last of DOJ’s Foreign Corrupt Practices Act (FCPA) Section also offered further explanation of the voluntary disclosure program. ![]() At the same conference, Glenn Leon, chief of DOJ’s Fraud Section, stated that DOJ expected to announce several criminal matters in the next several days that would provide clarity about what DOJ expects in terms of the timeliness and content of voluntary disclosures of corporate wrongdoing. In particular, Deputy Attorney General (DAG) Lisa Monaco announced DOJ’s practice of encouraging clawbacks (i.e., money already paid out must be returned to the employer or the firm) and requiring compensation reforms as part of negotiated resolutions of criminal matters with corporations. These policy initiatives will continue to create challenges and uncertainty for corporations. On March 2-4, 2023, at the annual ABA National Institute on White Collar Crime, DOJ officials made a series of significant statements relating to the agency’s current focus on alleged corporate wrongdoing. Department of Justice has issued several policy memoranda and pronouncements setting forth factors federal prosecutors will consider when assessing corporate misconduct. ![]()
0 Comments
Leave a Reply. |