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The Department of Justice has come knocking and is investigating your company for let’s say –serious money laundering or sanction violations or for manufacturing a defective product that has caused injuries or deaths.
The press is bad, raising grave questions about the company’s culture. Emails released to the public show that employees are afraid to speak up for fear of retaliation, or worse, employees are hiding misconduct from the regulators.
It’s just a matter of time before your company settles charges with the government and is likely to pay a hefty fine. A deferred prosecution agreement and the potential imposition of a monitor is, well, looking like it’s on the horizon.
If your company finds itself in this position, your crisis management team should be asking itself what first steps we should take to demonstrate to the government or a potential future monitor that our company is committed to improving its culture and compliance program.
Here are some of the first remedial steps:
The above described steps are foundational for any compliance program and are necessary steps to take to demonstrate to the government and a potential monitor that the company is changing its ways.
Andrew J. O’Connell, President, Investigations and Private Client Protection
Andrew J. O’Connell specializes in regulatory compliance, monitoring and investigation enforcement matters. He has been involved in several large monitorship engagements including serving as the Deputy Monitor for General Motors and Deutsche Bank. He has served as an Assistant U.S. Attorney in the Southern District of New York where he prosecuted federal crimes, including various frauds and financial and electronic crimes. He was also a litigation attorney for an international law firm and a Special Agent with the U.S. Secret Service.
David H. Katz, Senior Managing Director
David H. Katz has more than 25 years of experience investigating and prosecuting complex frauds and examining and assessing compliance programs. He is an important member of the firm’s high profile monitorship practice, having most recently served as a member of the leadership team on the General Motors monitorship. He previously has held senior positions with the U.S. Senate’s Permanent Subcommittee on Investigations, the Internal Revenue Service, and the NASD (now FINRA). Mr. Katz began his career at the U.S. Department of Justice as a Trial Attorney for the Fraud Section of its Criminal Division in Washington, DC, investigating and prosecuting high profile white-collar cases.