The Monaco Memo: The Corporate Crime Advisory Group

At the end of October 2021, Deputy Attorney General Lisa Monaco announced a package of policy updates that could shake up DOJ enforcement. Additionally, she made clear that there might be other changes coming and announced that a new committee would be convened to advise on what changes can and should be made. However, in the more than four months since the announcement, little has been heard from the Corporate Crime Advisory Group (CCAG), nor have any new policies been announced. In this final article of our four-part series on the Monaco Memo we investigate why the CCAG could be helpful and what might come from it. The first article in the series looked at the reversion to previous standards for earning cooperation credit with regard to individuals; the second discussed its reemphasis on imposing monitors in criminal matters; and the third investigated the new directive that prosecutors consider all prior misconduct when making charging decisions. See “Trends in and Nuances of Negotiating NPAs, DPAs and Declinations” (Nov. 11, 2020).

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