In a recent speech, Deputy Attorney General (DAG) Lisa Monaco unveiled the Department of Justice’s top priorities for corporate criminal enforcement. The speech corresponded with the release of a memorandum (which has popularly been dubbed the Monaco Memo) revising the DOJ’s Corporate Criminal Enforcement Policies.
The Monaco Memo details a shift in DOJ’s enforcement priorities and further emphasizes the DOJ’s focus on individual accountability. The specificity of the DOJ’s guidance provides General Counsels and Chief Compliance Officers with an opportunity to educate key stakeholders on the value of greater investment in a company’s compliance program.
Here are three key takeaways from the guidance and four practical ways to align compliance programs to the recent DOJ guidance.