On March 2, 2018, Deputy Attorney General Rod Rosenstein delivered the keynote address at the American Bar Association’s National Institute on White Collar Crime, highlighting recent convictions, resolutions, and areas of focus for the DOJ.  In his prepared remarks, Rosenstein noted that the current administration was not relaxing its enforcement efforts targeting white collar crime, but added that DOJ will seek to “avoid imposing penalties that disproportionately punish innocent employees, shareholders, customers, and other stakeholders.”

In a separate panel discussion at the conference, John Cronan, DOJ’s acting Head of the Criminal Division, announced that DOJ will use the FCPA Corporate Enforcement Policy as “nonbinding guidance” in other areas of white-collar enforcement beyond the FCPA.  Cronan highlighted DOJ’s recent decision not to bring charges against Barclays Plc in connection with alleged front-running by a former employee, noting that the company self-disclosed the activity, agreed to repay $12.9 million in profits obtained as a result of the alleged scheme, and implemented enhanced compliance measures.

Remarks as Prepared
DOJ Expands Leniency Beyond FCPA (Law360)