In the past week, four high-ranking DOJ officials delivered speeches that indicated a potential increase in enforcement efforts against financial institutions. Suggestions from these individuals included enhancing whistleblower initiatives; increasing cooperation between civil and criminal divisions; prosecuting more individuals; offering more leniency for firms that maintain a top-notch compliance program, even if that program is improved after the problem occurred; and enhancing international cooperation.
In Compliance Week's article, "Justice Department Launches a Full-Court Press on Misdeeds at Banks," RK&O partner and former federal prosecutor David Massey reacted to remarks made by Leslie Caldwell, assistant attorney general for the Criminal Division, about a new policy in which qui tam complaints are shared by the Civil Division with the Criminal Division as soon as they are filed. "Merely as a result of giving that speech, she may source new work for the criminal side," Massey said.
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