Fairwords Weekly: Revamped Recordkeeping Requirements, Google Compliance Reforms, and Corporate Crime Guidance
November 10, 2022
“We expect good companies to step up and own up to misconduct. Voluntary self-disclosure is an indicator of a working compliance program and a healthy corporate culture.”
— General Lisa O. Monaco, Deputy Attorney, United States Department of Justice
Explore how a new audit trail alternative replaces the “WORM” format in the SEC’s updated broker-dealer recordkeeping requirements. Learn about the agreement in which Google must improve its compliance program due to a settlement with the U.S. Justice Department. Consider the DOJ’s new guidance for corporate enforcement policies to prioritize and prosecute corporate crime better.
Last month, the U.S. Department of Justice announced new guidance for the DOJ’s corporate enforcement policies. The new corporate crime guidance focuses on individual accountability, companies with a history of misconduct, a new policy on voluntary self-disclosures, compliance monitors, and promoting compliance and avoiding improperly risky behavior. How corporate crime is scrutinized, how prosecutors are empowered, and how companies do the right thing is a top priority for the DOJ. Companies must reinforce and update all compliance efforts, policies, and procedures. Employee training, continuing education, and data analytics are essential efforts to mitigate risks. Learn more about the changes the DOJ is implementing to further strengthen the prioritization and prosecution of corporate crime.