Building on attempts in recent years to strengthen the Department of Justice’s (DOJ’s) white collar criminal enforcement, on September 15, 2022, Deputy Attorney General Lisa Monaco announced revisions to DOJ’s corporate criminal enforcement policies. The new policies, and those that are in development, further attempt to put pressure on companies to implement effective compliance policies and to self-report if there are problems. Notably, the new DOJ policies set forth changes to existing DOJ policies through a “combination of carrots and sticks – with a mix of incentives and deterrence,” with the goal of “giving general counsels and chief compliance officers the tools they need to make a business case for responsible corporate behavior” through seven key areas:
Blog Editors
Recent Updates
- Complex Billing and Reasonable Interpretations: Jury Was Entitled to Find Fraud in Doctor’s Upcoding of Speedy COVID-19 Tests, Fourth Circuit Says
- Governor Kotek Signs Oregon’s SB 537, Strengthening Workplace Violence Prevention in Health Care
- From Best Practices to Enforcement: Decoding DOJ’s July 29 Anti-Discrimination Guidance
- HRSA Seeks Applicants to Test 340B Rebate Model Pilot Program
- CMS Proposes Mandatory Ambulatory Specialty Model to Advance Value-Based Care for Chronic Conditions