Assistant AG Polite Discusses Declinations in Cases With Aggravating Circumstances and Revised ECCP

The DOJ recently updated both its Corporate Enforcement and Voluntary Self-Disclosure Policy and its Evaluation of Corporate Compliance Programs. In a March 23, 2023, keynote address at the Spring conference of the Global Investigations Review, Assistant Attorney General Kenneth A. Polite, Jr., discussed the genesis and impact of those updates. Stressing the DOJ’s desire to be transparent about its efforts to promote good corporate citizenship, Polite focused on the availability of declinations in cases with aggravating circumstances and the requirement for “immediate” self-reporting and “extraordinary” cooperation and remediation. This article distills the key takeaways from his speech. See “Corporate Enforcement Policy Revisions: A More Amenable DOJ Looks to Negotiate” (Feb. 1, 2023).

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