By Sharon McCarthy and Christopher Ferguson
American Bar Association Criminal Justice Section, The White Collar Crime Committee Newsletter
Summer/Fall 2023 Edition
We are all familiar with the aphorism that those who forget history are condemned to repeat it.
The Department of Justice’s (“DOJ” or the “Department”) recent amendments to its corporate
criminal enforcement policies, contained in two successive memoranda issued by Deputy Attorney
General (“DAG”) Lisa Monaco in October 2021 (“Monaco I”) and September 2022 (“Monaco II”)
(together, the “Monaco Memos”), suggest that the Department has forgotten history.
This article was published in The White Collar Crime Committee Newsletter, Summer/Fall 2023 Edition, published by the American Bar Association Criminal Justice Section.
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