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Years ago, when trying to improve some of my snacking habits, I stopped buying cookies, candy and savory chips. Magically (and perhaps obviously), I quickly found that I ate less junk food. In effort to find a few more minutes a day for marketing, I recently applied this same basic, but effective, technique to my time management and the results have been just as immediate.
Similar to the many professionals I coach, time is my universal excuse for skipping business development. That said, I recognize that if I don't spend the time focusing now, I will spend too much of it worrying later. So, at the beginning of the year, I conducted a self-assessment and realized that I waste a few minutes a day (ok, maybe longer) reading the news.
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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.
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.
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 explores legal developments over the past year that may impact compliance officer personal liability.
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