Partner Sandra Moser spoke to Law360 about the new era of corporate enforcement that will be seen in 2022, following the announcement of new Department of Justice (DOJ) corporate criminal policies unveiled last year. “The department doesn’t want to limit itself,” Sandra said, regarding a new policy that requires companies to name every person potentially involved in misconduct, even those of lower rank in the organization. “Sometimes you get incredibly valuable information from lower-level people, not only about how a scheme might work but also who's giving the orders. If you start at 'substantially' involved, there might be a good chunk of people you miss.”
Sandra also spoke about the DOJ’s declaration of global corruption as a national security risk and the strategic, multiagency plan to tackle it. “The deployment of resources to the relevant agencies, including DOJ — as opposed to the tradition of ‘doing more with the same’ — will be critical to seeing any one of these strategic objectives succeed,” Sandra said.