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DOJ Talks Tough After Enforcement Ticks Down, Agenda

October 03, 2022

Partner Daniel Tehrani spoke with Agenda following a speech made by Deputy Attorney General Lisa Monaco announcing a set of US Department of Justice policies aiming to encourage companies to quickly self-disclose misconduct and employ compensation clawback measures to deter bad actors.

The key points Monaco emphasized in her speech were “individual accountability and speed,” Daniel noted.

In the US Department of Justice’s (DOJ’s) view, these two points “go hand in hand,” he said.

“A way to hold individuals accountable is to speed up investigations both on the company’s side and also on the prosecutors’ side.”

To underscore that point, Daniel noted another policy announcement from Monaco’s speech instructing prosecutors to complete criminal investigations into individuals before resolving any charges against the corporation.

Monaco’s new guidelines could “empower compliance professionals to demand or make the business case for investments in compliance,” he said.

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