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On March 2, 2018, in remarks delivered at the 32nd Annual ABA National Institute on White Collar Crime, Deputy Attorney General Rod Rosenstein outlined some of the DOJ's white collar crime priorities, and touted some accomplishments, which also may shed light on priorities. These included:
Punish Wrongdoers, Not Entities. Mr. Rosenstein reiterated that the DOJ is interesting in punishing wrongdoers, not entities and innocent bystanders, and is committed to finding effective ways to ensure that individual wrongdoers who make or knowingly participate in decisions to violate the law are held accountable for corporate criminal misbehavior. But the DOJ wants to avoid imposing penalties that disproportionately punish innocent employees, shareholders, customers, and other stakeholders.
Effective Compliance Programs. He also suggested that American corporations increasingly devote resources to compliance and oversight efforts designed to deter crime and to protect their brands proactively. Hence, the DOJ wants to reward companies that invest in strong compliance measures. He added that when something goes wrong, the greatest consideration should be given to companies that do not just adopt compliance programs, but incorporate them into the corporate culture. "If you want us to treat a corporate entity as a victim, you should act like a victim who wants to see the perpetrators held accountable."
You may read Mr. Rosenstein's full remarks on the DOJ's website.
For more information about this update, or if you have any questions regarding Bryan Cave Leighton Paisner's White Collar Defense and Investigations Client Service Group please contact Mary Beth Buchanan, Joey Burby, Austin Campriello, Richard Finneran, Mark Srere, or Cliff Stricklin.