Does DOJ Actually Recognize Need for Better “Rules of the Road” for Corporate Enforcement?

In a speech in Brazil, Principal Deputy Assistant Attorney General John Cronan asserted that DOJ recognizes “the need for better defined ‘rules of the road’ in corporate enforcement” and that the department “has taken affirmative steps to make [the] prevailing ‘rules of the road’ as plain and predictable as possible.” As evidence, Cronan pointed to DOJ’s November 2017 Corporate Enforcement Policy.