On May 12, Assistant Attorney General Caldwell addressed the Fourth Annual White Collar Crime Institute.  Her remarks focused on DOJ’s expectations with respect to corporate cooperation with government investigations.  Caldwell emphasized that the Principles of Federal Prosecution of Business Organizations (known as the Filip Factors) provide guidance as to DOJ’s expectations with respect to corporate cooperation and noted that DOJ expects corporations to conduct investigations that focus on the problem at issue, determine the scope of that problem and investigate accordingly, and also focus on what compliance or cultural shortcomings failed to identify the problem. She further stated that DOJ expects corporations to help remove barriers to identifying and producing relevant information that DOJ requires. Next, Caldwell addressed cooperation between DOJ and its enforcement and regulatory partners, noting a potential for unfairness when a company is asked to pay multiple fines to different agencies for effectively the same conduct, and commenting that cooperation across the board, with both the DOJ and its regulatory partners, increases the likelihood for a coordinated, simultaneous resolution of multiple investigations. Finally, Caldwell noted that the DOJ would continue to strive to be more transparent in setting forth the factors, considerations and rationales behind its resolutions.