On September 15, 2022, the Department of Justice (Department) released a memorandum revising several key aspects of its corporate criminal enforcement policies. The new policy, titled Further Revisions to Corporate Criminal Enforcement Policies Following Discussions With Corporate Crime Advisory Group (the September 2022 Revised Policy) prioritizes four areas: (1) individual accountability, (2) corporate accountability, (3) independent compliance monitors and (4) a commitment to transparency. The new policy builds on the foundation laid in the October 2021 Memorandum on Corporate Crime Advisory Group and Initial Revisions to Corporate Criminal Enforcement Policies (October 2021 Memorandum) and its contours were 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. Deputy Attorney General Lisa Monaco previewed the key themes of the new policy in a speech at NYU School of Law’s Corporate Compliance Enforcement Program on September 15, 2022.
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