Can your company keep a promise to cooperate?
7:48 am Why is cooperation in corporate enforcement actions such a big deal? Because from the outside, most companies are a black box. Without help, it’s impossible to know what happens inside. The DOJ’s Justice Manual (the handbook for federal prosecutors) describes “several obstacles” that can hinder a corporate investigation. Among the obstacles are informal lines of authority, documents and data spread worldwide, and promotions, transfers, firings, resignations, and retirements that disburse key players. “ Accordingly, a corporation’s cooperation may be critical in identifyin...