Womble Bond Dickinson – DOJ recently announced white-collar crime enforcement priorities and significant changes to its corporate enforcement policies. “[O]verbroad and unchecked corporate and white-collar enforcement burdens U.S. businesses and harms U.S. interests,” and “[n]ot all corporate misconduct warrants federal criminal prosecution,” according to the memo. New changes to these DOJ policies are intended to help companies navigate what to expect when making a disclosure and clarify the additional benefits that are available to companies that self-disclose and cooperate. As noted in the post, given these revised priorities, firms should review policies and procedures to address increased emphasis on money laundering, sanctions compliance, human rights violations, and financial fraud.
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