Recent US Department of Justice Commentary and the Impact on Compliance

What does the Deputy Attorney General’s recent comments about various Department memorandum and informal statements mean for compliance and ethics. For more information on the DAG’s October statement, you can review this excellent commentary. The statement suggests that many of the DOJ memos discussing corporate prosecutions we are familiar with may be consolidated (or revoked). The DAG has suggested all commentary should be within the US Attorney’s Manual. But Eric points out that the process of updating the USAM may take some time. There may also be some opportunity for the community to make its opinions known about any changes or additions before the process is finished. The bottom line is that the compliance and ethics community should pay attention to this process and any possible changes.