DOJ's New Policy on Coordination of Corporate Resolutions Aims to Reduce “Piling On”
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Key takeaways:
- The U.S. Department of Justice this week announced a new policy regarding the coordination of corporate resolutions, which provides that DOJ should consider penalties imposed by other enforcement authorities.
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While the new policy is light on detail and contains few surprises, the stated intention to improve coordination is laudable. Better coordination among U.S. authorities and with foreign counterparts would represent a significant step forward.
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It remains to be seen whether the new policy will provide the type of finality that companies understandably seek, as well as how authorities will better coordinate and apportion penalties.