Principal Deputy Assistant Attorney General John P. Cronan of DOJ’s Criminal Division delivered wide-ranging remarks at three separate events in October and November, outlining for audiences the policy rationales and practical considerations of several DOJ policies.  In particular, Cronan highlighted the use of the FCPA Corporate Enforcement Policy as “nonbinding guidance” in non-FCPA cases, stressing the importance of early self-disclosure and the need to provide a “regular and consistent flow” of information as internal investigations progress.  Cronin also explained how DOJ seeks to reward companies that take “meaningful, effective compliance seriously,” using two Bank Secrecy Act deferred prosecution agreements as examples of instances where effective compliance programs could have detected problems sooner.  Finally, Cronan reiterated DOJ’s emphasis on holding individuals accountable, highlighting several recent FCPA prosecutions of individuals.

Remarks as Prepared (Oct. 18, 2018)

Remarks as Prepared (Oct. 25, 2018)

Remarks as Prepared (Nov. 28, 2018)