Filip Factor Presentations in the Wake of the Monaco Memo

In October 2021, the Monaco Memo had a significant impact on the factors influencing corporate settlements, and there are hints that there are additional policy changes to come. In a guest article, Alston & Bird partners Brian Frey and Albert (BJ) Stieglitz explain how companies and their counsel should calibrate their advocacy during Filip Factor presentations to these newly articulated DOJ priorities and appetites. They discuss two recent corporate settlements that provide early indications that DOJ intends to follow through on the tough rhetoric in and surrounding the Monaco Memo and tips on how to meet the heightened standards for earning cooperation credit. For more from Alston, see “Cryptocurrency and Corruption: The Future of FCPA Enforcement?” (Mar. 31, 2021).

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