s manual entitledEvaluation of Corporate Compliance Programs(the “Compliance Guidelines”), provides guidance to prosecutors and, indirectly, to corporate compliance professionals regarding the elements and features of a corporate compliance program that federal prosecutors look for during corporate criminal ...
Additionally, it is often unclear at the outset of a matter whether prosecutors will consider a company's compliance program and controls to be effective at the time of self-disclosure. This uncertainty, coupled with the risk of potential subsequent investigations by the SEC, domestic regulato...
First, Monaco stated that prosecutors would be able to seek increased penalties for criminals who “deliberately misuse AI to make a white-collar crime significantly more serious—for individual and corporate defendants alike.” Referring to AI’s potential to effect “...
The new guidance confirms that prosecutors are to consider whether (1) the compliance program is well designed (providing a clear message that misconduct is not tolerated; having appropriate policies and procedures to detect and prevent the most likely types of misconduct given the company’s line ...
For special counsel Smith's part -- through public filings and statements from prosecutors in court, he has repeatedly avoided direct mentions of the November election as influencing his decisionmaking. Instead, he has pointed to the "public's interest" in seeing the charges against Trump quic...