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Benesch says it reviewed DOJ’s corporate fraud enforcement directive
Benesch said it published an analysis of the Justice Department’s October 1 corporate fraud enforcement directive. The firm said the memorandum centralizes corporate investigations through the National Fraud Enforcement Division’s Corporate Enforcement Section and identifies ten factors prosecutors must weigh in charging and plea decisions.
Key points
- Benesch said ongoing investigations must be reported to the Corporate Enforcement Section within seven days.Benesch
- The firm said priority areas include healthcare, government contracting, tax and trade fraud.Benesch
- Benesch said weighted factors include losses of at least $25 million or harm to at least 25 victims.Benesch
- The firm said the directive calls for developing additional whistleblower incentives.Benesch