In September, U.S. Department of Justice (DOJ) Deputy Attorney General Lisa O. Monaco announced new guidelines the department will use in connection with criminal enforcement. Those guidelines, described in a September 15 memorandum entitled “Further Revisions to Corporate Criminal Enforcement Policies,” reflect a thoughtful consideration of input DOJ received since announcing in 2021 that plans were underway for revising these guidelines and creating the Corporate Crime Advisory Group (CCAG).^[1]

CCAG held many meetings with outside experts representing numerous interested parties, from in-house attorneys to academics, members of the business community and defense bar, ethicists, audit committee members, and public interest groups. I was pleased to represent SCCE in one of these listening sessions.