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I married at the age of 24, between my second and third year of law school. As a practicing Catholic, I went to the mandated pre-marriage counseling classes, where my fianc' and I were surrounded by younger brides and grooms. Now, over 30 years later, it is dramatic to notice the drop in the number of weddings. There is a distinct rise in the age of couples getting married. Often, we hear about young people who decide to have children out of wedlock and begin a family without the benefit of a spouse. Are these trends a quirk of my community and my experience? Absolutely not.
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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.