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Over the last few weeks, we have seen a lot of ink relating to a certain merger that didn't happen. Everyone is speculating on why it didn't happen and what the fallout will be for both firms. Some have opined both in print and on blogs that the firm who has lost the most in terms of talent will be weakened and without a clear vision to move forward
From where I am sitting, I can attest to the fact that there is a light at the end of the tunnel for that firm. I know this because I experienced first hand how a firm can recover from 'the worst of times.'
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The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
The parameters set forth in the DOJ's memorandum have implications not only for the government's evaluation of compliance programs in the context of criminal charging decisions, but also for how defense counsel structure their conference-room advocacy seeking declinations or lesser sanctions in both criminal and civil investigations.
This article discusses the practical and policy reasons for the use of DPAs and NPAs in white-collar criminal investigations, and considers the NDAA's new reporting provision and its relationship with other efforts to enhance transparency in DOJ decision-making.
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This article explores legal developments over the past year that may impact compliance officer personal liability.