Should Compliance Programs Relax When DOJ Enforcement Slows Down?

When it comes to DOJ enforcement, the pendulum swings, and it always returns. Don’t let it knock you off your feet. I’ve been watching the headlines, and so have you. Fewer corporate guilty pleas, non-prosecution agreements for Alibaba and Eagle Bank, charges dropped against Boeing and Halkbank from Turkey. The word from Main Justice is: hold individuals accountable, go easier on companies. I get why some executives are breathing a sigh of relief. But here’s my message to every compliance officer out there: do not read this as permission to relax. Enforcement priorities are cyclical. Administrations change. Statutes of limitations run long. The conduct you tolerate today under a lenient DOJ can absolutely come back across your desk in the future, with a lookback period that reaches right back to right now. And let’s not forget: non-prosecution agreements still require admissions, still require massive fines, and still require you to fix your program. They’re not a free pass. That’s a warning shot. Stay vigilant. Keep building your program like the next administration is already watching, because eventually it will be. The Ethics and Compliance Q and A show is produced by One Stone Creative.