In March, Deputy Attorney General (DAG) Lisa Monaco reviewed a number of initiatives by the DOJ that every compliance professional needs to study in some detail. These new initiatives included: (1) The Criminal Division's Pilot Program Regarding Compensation Incentives and Clawbacks; (2) Evaluation of Corporate Compliance Programs; and (3) Revised Memorandum on Selection of Monitors in Criminal Division Matters.

Monaco set the tone for the week by identifying five general areas of DOJ focus. (1) Inspiring a Culture of Compliance; (2) Voluntary Self-Disclosure Programs; (3) Promoting Compliance through Compensation and Clawback Programs; (4) Resource Commitments to Corporate Criminal Enforcement; and (5 ) Individual Accountability. 

Three key takeaways:

1. A culture of compliance continues to be the most important component of DOJ review.  

2. Self-disclosure will be the number one factor for reducing a potential fine and penalty. 

3. Expect more individual accountability.   

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