Two weeks ago, the U.S. Department of Justice (“DOJ”) announced broad changes to its policies on corporate criminal enforcement. The changes were outlined in a memorandum entitled Further Revisions to Corporate Criminal Enforcement Policies Following Discussions With Corporate Crime Advisory Group (“Revised Policies”) and were accompanied by a public statement by Deputy Attorney General Lisa Monaco. Last week, Principal Associate Deputy Attorney General Marshall Miller gave a Keynote Address (“Keynote”) at Global Investigations Review in New York City, which augmented Monaco’s remarks.3 The Revised Policies and these public statements merit serious consideration by in-house and outside counsel who conduct internal investigations.
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