The Corporate Crime Advisory Group Has Spoken: DOJ Revises Corporate Criminal Enforcement Policies

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The Corporate Crime Advisory Group Has Spoken: DOJ Revises Corporate Criminal Enforcement Policies

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On September 15, 2022, the Department of Justice released the memorandum, Further Revisions to Corporate Criminal Enforcement Policies Following Discussions with Corporate Crime Advisory Group. It prioritizes four areas: (1) individual accountability; (2) corporate accountability; (3) independent compliance monitors; and (4) a commitment to transparency and was informed in part by a series of meetings between the Corporate Crime Advisory Group (“CCAG”) and civil society groups, criminal law experts, in-house counsel, and business leaders, among other stakeholders, to discuss corporate enforcement. Among other goals, the policy intends to provide General Counsels and Chief Compliance Officers the tools needed to make the business case for compliance, to further incentivize robust self-disclosure, and to provide prosecutors additional guidance and resources to pursue Department priorities in the four key areas noted above.  

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