Keith Rosen (US)

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US DOJ announces corporate criminal enforcement policy revisions

Following Deputy AG Lisa Monaco’s remarks at the White Collar Conference last year, the Department of Justice (DOJ) created a Corporate Crime Advisory Group to revise DOJ’s Corporate Criminal Enforcement Policies. On September 15, 2022, Monaco announced the group’s first major round of revisions. The revisions reiterate a focus on individual accountability, voluntary disclosure, and … Continue Reading

U.S. Strategy on Countering Corruption: Key points for international companies

On 6 December 2021, the Biden Administration released its strategy on countering corruption (the Strategy) along with an accompanying fact sheet, building on President Biden’s earlier announcement that he viewed the fight against corruption as one of the core U.S. national security priorities.  The five-point strategy places particular focus on a coordinated international approach to … Continue Reading

New US DOJ guidance on corporate compliance programs emphasizes dynamic program design and implementation

During the summer, the United States Justice Department announced the latest set of updates to its “Evaluation of Corporate Compliance Programs” policy. The policy, which was first released in 2017 and revised last year, provides companies with detailed guidance on how the Department will review the adequacy and effectiveness of compliance programs when making charging … Continue Reading
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