![]() ![]() She stressed that DOJ needs to move more quickly in its investigations of individual corporate officials. If DAG Monaco’s speech had a primary emphasis, it was on the speed of DOJ’s investigations. ![]() Cooperation Credit and the “Timely” Disclosure of Information Learned in Internal Investigations New Guidelines For Independent Corporate Monitor Processġ.Guidance for Corporations with Prior Misconduct Resolutions (Criminal and Non-Criminal).Delaying Corporate Resolutions Until DOJ’s Investigation of Individuals Is Completed.DOJ Scrutiny of Discrete Corporate Policies – Including Executive Compensation Policies – In Assessing Compliance Programs.Clarifying (In the Future) How To Earn Maximum Cooperation Credit.Clarifying (In the Future) the Benefits of Voluntary Self-Disclosure.Cooperation Credit and the “Timely” Disclosure of Information Learned in Internal Investigations.The Memo and accompanying speeches also provide important insights into how corporations can expect DOJ to analyze some of the key concepts in federal corporate enforcement, including “cooperation credit” and “voluntary self-disclosure.” And in some areas, the Monaco Memo breaks new ground with detailed DOJ guidance. A close look at the Monaco Memo in the context of DOJ’s existing Corporate Enforcement Policy shows that the changes to DOJ’s policies are on discrete topics, but some of these changes signal that DOJ is implementing a substantial shift toward a more aggressive approach in corporate crime matters – especially in terms of DOJ’s expectations for the pace of corporate internal investigations and related disclosures to DOJ. The immediate reporting on DAG Monaco’s speech and the Monaco Memo tended to highlight her statements that DOJ would no longer engage in “business as usual” regarding its investigations of corporations and corporate officials, and that DOJ was now instituting its first-ever “department-wide policies” on some areas. The September 15 release of the Monaco Memo was accompanied by a speech the same day by DAG Monaco and a speech the next day by the head of the DOJ Criminal Division, Assistant Attorney General Kenneth Polite. Department of Justice’s Deputy Attorney General, Lisa Monaco, issued a 15-page memo discussing revisions to DOJ’s heavily-scrutinized Corporate Enforcement Policy. ![]()
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