Partner Daniel Tehrani was quoted in a Global Investigations Review article on uncertainty around the outcome of the changes to the US Department of Justice’s (DOJ’s) corporate enforcement policies. While Deputy Attorney General Lisa Monaco’s remarks last month discussing the changes gave some level of predictability, lawyers said they contained caveats that give prosecutors leeway in applying new policies in specific cases.
Daniel told the publication that the DOJ could help lawyers by spelling out their charging decisions.
“I think it will depend on the DOJ to demonstrate very clearly when companies benefit and when they don’t and when they are effectively punished for not having adequate compliance [programs] or not coming forward,” Daniel said.