Assistant Attorney General for the Criminal Division Leslie R. Caldwell, recently spoke at the 22nd Annual Ethics and Compliance Conference and the FCPA Conference and the 2014 FCPA Conference.
There were three themes to her comments in the two speeches:
- Aggressive prosecutions
- International cooperation between countries has increased
- Cooperation with the DOJ is is a factor in sentencing guidlines
Below are some of her highlights from her two speeches.
- The World Bank estimates that more than $1 trillion is paid every year in bribes, about 3% of the world economy.
- In our fraud, corruption, money laundering, & sanctions cases, we have seen too many failures of corporate compliance.
- More often, we encounter companies with compliance programs that are strong on paper, but much weaker in practice.
- Perfect compliance in this increasingly global economy is incredibly difficult.
- Sentencing Guidelines expressly include a company’s corporate compliance program as a factor in corporate sentencing.
- Prosecutors must consider “the existence and effectiveness of the corporation’s pre-existing compliance program.”
- Sentencing Guidelines expressly include a company’s corporate compliance program as a factor in corporate sentencing.
- Since 2009, we have convicteded more than 50 Individuals in FCPA and FCPa related cases, and resolved criminal cases against more than 50 companies with penalties and forfeiture of approximatly 3 Billion. Twenty-five of the cases involving individuals came since 2013 alone.
You can view the complete text from Leslie R. Caldwell speeches by clicking the links below:
Full text from the 22nd Annual Ethics and Compliance Conference and the FCPA Conference