March 7, 2019

Deputy Attorney General Rod Rosenstein discusses FCPA enforcement

Delivering the keynote address at an FCPA conference in Washington, D.C., Deputy Attorney General Rod Rosenstein emphasized the individual accountability policy that informs the enforcement practices of the Department of Justice.  He defended against critics who claim that the DOJ has “gone soft” on corporate crime, saying that the most effective way to deter corporate criminal misconduct is to identify the individuals who commit crimes, and send them to prison.  Rosenstein said that the DOJ’s aim is to incentivize companies to report crimes, disgorge illegal proceeds, take remedial action, and identify the accountable individuals so that they can be prosecuted.   The Deputy Attorney General also reiterated the DOJ’s policy to avoid government agencies’ piling on multiple penalties for the same conduct, explaining that it saves resources, prevents duplicative fines, penalties and forfeitures, and provides certainty and finality for companies. In conclusion, Rosenstein stressed the importance of effective compliance programs implemented in good faith, and a culture of integrity.

Dep. AG speech