Recent DOJ Policy Announcements Podcast By cover art

Recent DOJ Policy Announcements

Recent DOJ Policy Announcements

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 Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. Today, I welcome back James Tillen and Ann Sultan, both partners at Miller & Chevalier. We take a deep dive into four recent DOJ Policy announcements: FCPA Enforcement, White Collar Enforcement, Criminal Enforcement Policy and Whistleblower Pilot Program. New DOJ Policy Memorandum We take a deep dive into Deputy Attorney General Todd Blanche’s Memo on Investigations and Enforcement of the FCPA. We review the stated main goals of the DOJ and how are prosecutors supposed to achieve these goals. We consider the 3 directives to prosecutors: focus on cases with individual misconduct, proceed expeditiously, consider collateral consequences. We look at the White Collar Plan and CEP and ask if we moved from a presumption of a declination to a more tangible framework? We conclude by reviewing what compliance professionals need to be thinking about and looking into now. Key Highlights IncludeHow does the principle of "not attribute[ing] nonspecific malfeasance to corporate structures" impact potential prosecutions of companies and individuals? And how do these priorities jive with other DOJ priorities, such as prosecuting cartels/transnational criminal organizations? What does it mean for companies that the DOJ is prioritizing “serious misconduct”? What are the implications of the DOJ’s stated intent to avoid penalizing “routine business practices in other nations”? Do you see this as a shift in focus for the DOJ to non-US companies? Other DOJ Priorities & Announcements Policy Shifts and Clarifications Looking Ahead: What’s on the Horizon Resources FCPA Spring Review 2025 – Miller & Chevalier DOJ Criminal Division White Collar Plan Guidelines for Investigations and Enforcement of the FCPA Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the use of AI in Compliance programs, my new book, Upping Your Game. You can purchase a copy of the book on Amazon.com Learn more about your ad choices. Visit megaphone.fm/adchoices
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