DOJ's First Decision Not to Prosecute Healthcare Company Under New Policy Carries Lessons, Corporate Counsel

Corporate Counsel spoke with partner Heidi Manschreck about the US Department of Justice’s (DOJ’s) first decision under a new department-wide policy to decline prosecution of a healthcare company that voluntarily disclosed misconduct and cooperated with the government.

Heidi emphasized the importance of having systems in place to identify potential misconduct early.

“Having a strong compliance program that can lead to early detection of misconduct so that you’re in a position to take advantage of policy like this is really important,” she said.

Heidi added that companies seeking a declination should be prepared to cooperate with prosecutors, including in investigations involving high-ranking individuals.

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