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:
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Medicaid and Medicare fraud
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Military procurement fraud
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Illegal offshore tax shelters
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The fraudulent failure to pay payroll taxes
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Fraudulent transactions involving tax credits for renewable fuels
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Manipulation of the securities markets
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Other forms of fraud that threaten the integrity of America’s financial system
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Financial institutions that ignore evidence that customer transactions were related to international narcotics and money laundering activities
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.
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