2022 Update to Corporate Criminal Enforcement Policies: A Primer

On September 15, 2022, the U.S. Department of Justice (DOJ) released a memorandum titled “Further Revisions to Corporate Criminal Enforcement Policies." Authored by Deputy Attorney General Lisa Monaco, the memorandum expands upon DOJ initiatives announced in the fall of 2021 aimed at reinforcing the principle of individual accountability for corporate crime, promoting a holistic consideration of a corporation’s history of misconduct, and expanding the circumstances under which federal prosecutors might require the use of corporate monitors.

Applicable across the DOJ, the Enforcement Update announces several new crucial changes to the manner in which federal prosecutors apply existing criminal enforcement policies. The Enforcement Update is divided into four main sections and provides additional insight into the DOJ’s approach to:

  • Both individual and corporate accountability
  • The utilization of corporate monitorships
  • The DOJ’s commitment to transparency in corporate resolution decisions.

Read the full white paper for an in-depth look at the ramifications of the Enforcement Update.