On May 12, the U.S. Department of Justice (DOJ) issued updated policy memoranda relating to the investigation and prosecution of white collar crimes, including its White-Collar Enforcement Plan, Revised Corporate Enforcement and Voluntary Self-Disclosure Policy, Memorandum on Selection of Monitors in Criminal Division Matters, and the Criminal Division’s Corporate Whistleblower Awards Pilot Program Revisited. These memoranda should guide companies, executives, and compliance professionals in handling matters relating to their operations, compliance, reporting obligations, and potential investigations and prosecution.
This client update outlines our top five takeaways from the memoranda:
- Trade Crimes Enforcement Is a New Major Focus
- Waste, Fraud, and Abuse of Government Programs and Procurement Fraud Remain Top Priorities
- Companies in International Supply Chains Face Unique Challenges
- Corporate Self-Disclosure Requires Strict Compliance and Forthright Disclosures
- It’s Never Too Early to Engage White Collar Counsel