A Look into DOJ’s Current Corporate Criminal Enforcement Landscape

Sheppard Mullin – In recent remarks, Principal Associate Deputy Attorney General Marshall Miller shed light on various key areas of DOJ’s enforcement focus, including DOJ’s continued encouragement of voluntary self-disclosure and increasing attention towards safeguarding national security interests.

Miller also emphasized DOJ’s commitment to consistency, predictability and transparency in its corporate enforcement work with an aim that such commitment will help companies better predict outcomes for certain criminal violations and implement robust compliance programs to prevent criminal prosecution. Through its new voluntary self-disclosure policy, DOJ also now defines precise requirements for a company to obtain a presumption of a declination by self-reporting. This is even available for companies with, what Miller called, “aggravating circumstances.”

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• Sheppard Mullin: A Look into DOJ’s Current Corporate Criminal Enforcement Landscape