New Fraud Section Guidelines
Show notes
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore them more fully. Looking for hard-hitting compliance insights? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the DOJ’s new Fraud Division enforcement priorities.
The DOJ’s Fraud Division enforcement priorities matter because they can quickly reshape a company’s compliance risk, especially when prosecutors are told to focus on patterns like widespread victimization, large losses, senior management involvement, and obstruction of investigations. Tom argues updates are a practical cue for compliance leaders to reopen discussions with senior management, the audit committee, and the board, while also treating whistleblower incentives and even political risk as real factors on the company risk register. Matt similarly argues that the DOJ’s new posture has changed enforcement risk and that companies should respond by refreshing risk assessments, sharpening internal controls, and briefing leadership before problems become more costly. Both perspectives are shaped by their long experience covering corporate compliance and enforcement, with Fox emphasizing proactive governance and Kelly stressing the need to translate DOJ signals into concrete, business-specific risk management.
Key highlights:
- 10-Factor Fraud Prosecution Memo for Corporations
- Multiple Small Fraud Indicators, Material Weakness Risk
- DOJ Shift Raises Compliance Costs and Stakes
- Declinations for Companies That Voluntarily Self-Disclose
- Corporate Enforcement Section and 2024 ECCP
Resources:
Matt in Radical Compliance
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has received Davey, Communicator, and W3 Awards, all for podcast excellence.
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