Episode 5 speakers Jon Kolodner and Lisa Vicens co-authored a piece with Cleary Gottlieb colleagues in November 2021 entitled “DOJ Announces First Set of Revisions Strengthening Corporate Criminal Enforcement Policies”.  The piece discusses a new DOJ Memorandum and states, among other things:

“This initial set of changes to the DOJ’s corporate enforcement policies signals what most expected from the new administration:  a renewed and aggressive focus on and approach to corporate misconduct.  For a company facing criminal investigation, therefore, advocacy around these issues – such as which individuals were ‘involved’ in misconduct, the relevance of prior criminal conduct, and whether a monitor is warranted – will be of critical importance.”