Policy Shifts at the Department of Justice – 2018 in Review

January 2019
Region: Americas

In 2018, the US Department of Justice (DOJ) issued a number of important policy updates and rollouts that will have long-term and far-reaching impact. Although public attention may focus on personnel changes and the Robert Mueller investigation, we highlight other significant developments, focusing on the realm of government investigations and white collar prosecution. This alert also sheds light on what the policy shifts may mean for companies interfacing with the DOJ in the coming year.

Our review covers the topics below:

  • Debut of the Justice Manual
  • False Claims Act Developments
  • Foreign Corrupt Practices Act Policy on M&A and Successor Liability
  • Extraterritorial Limits of the FCPA
  • Emphasis on International Cooperation
  • DOJ Relaxes All or Nothing Yates Memo
  • Reducing Duplicative Penalties
  • Considerations for Corporate Monitorships
  • China Initiative: How Recent Fallouts Will Affect Business