Partner Dan Tehrani spoke with The Am Law Litigation Daily following a speech made by Deputy Attorney General Lisa Monaco providing updates on US Department of Justice (DOJ) policies, allowing prosecutors to consider how quickly a company reports potential misconduct.
“[S]peed for speed’s sake can be a bad thing,” Dan said regarding Monaco’s comments on expediting the DOJ’s investigations of individuals.
According to Dan, the new guidelines lay out investigative plans and oversight focusing on speeding probes of individuals and bringing prosecutions where warranted.
He noted that the new guidance could incentivize a company to provide information before fully evaluating its own internal investigations, potentially resulting in releasing information prematurely or taking action against employees to demonstrate cooperation and compliance when not warranted.
“[That] may not have happened if the company could have been more deliberative about the process,” he said.
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