Unsurprisingly, when set against this backdrop, Monaco's September speech highlighted the DOJ's intent to no longer accept 'business as usual' when investigating corporations and corporate officials.
Calling the policies 'a combination of carrots and sticks,' the DOJ's changes are designed to give organisations' Compliance Officers the tools to do the right thing regarding responsible corporate behaviour and empowers prosecutors to hold non-compliant businesses accountable.
Given this tougher stance, it's more critical than ever that US organisations thoroughly review their compliance procedures to ensure they don't fall foul of the DOJ's new priorities. The five key takeaways businesses need to be fully aware of are:
1. Individual accountability
2. History of misconduct
3. Voluntary self-disclosure
4. Independent compliance monitors
5. Company culture and compensation incentives