On 22 February 2023, the US Department of Justice announced a new voluntary self-disclosure policy for corporate criminal enforcement in all 94 United States Attorneys’ Offices across the country. This new voluntary self-disclosure policy is a response to Deputy Attorney General Lisa Monaco’s 15 September 2022 Memorandum insisting all DOJ divisions develop a self-disclosure policy, to the extent one does not already exist. Other DOJ components, including the Criminal Division, have already taken steps to issue or update their own policies on this topic.

On 22 February 2023, the US Department of Justice (DOJ) announced a new voluntary self-disclosure policy for corporate criminal enforcement in all 94 United States Attorneys’ Offices (USAOs) across the country.

This new voluntary self-disclosure policy is a response to Deputy Attorney General Lisa Monaco’s 15 September 2022 Memorandum (“Monaco Memo”) insisting all DOJ divisions develop a self-disclosure policy, to the extent one does not already exist. Other DOJ components, including the Criminal Division, have already taken steps to issue or update their own policies on this topic.

The current global sanctions environment — the new normal for Swiss companies: This was the topic of a Russia-focused seminar with members of Baker McKenzie’s global sanctions and investigations team, on 7 February 2023.

On 15 September 2022, Deputy Attorney General Lisa Monaco issued a memorandum to Department of Justice prosecutors entitled “Further Revisions to Corporate Criminal Enforcement Policies Following Discussions with Corporate Crime Advisory Group”. As has become common in recent years (with a brief intermission under Deputy Attorney General Rod Rosenstein who objected to the practice), such memoranda and other Department pronouncements have come to herald key developments in DOJ policy on corporate criminal enforcement and related practice. These memoranda are therefore closely watched by the defense bar and corporate counsel alike.