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Fried Frank says it reviewed DOJ’s new corporate fraud enforcement directive
Fried Frank said it published a client memorandum on DOJ’s October 1 corporate fraud enforcement directive. The firm said the directive requires prosecutors in the National Fraud Enforcement Division to work with its Corporate Enforcement Section throughout corporate investigations and emphasizes fraud involving government funds, healthcare and trade.
Key points
- Fried Frank said ongoing corporate investigations must be reported to the section’s chief within seven days.Fried Frank
- The firm said the section will evaluate compliance with corporate resolutions.Fried Frank
- Fried Frank said charging factors include management involvement, concealment, duration, victim numbers and financial loss.Fried Frank
- The firm said the directive calls for policies that encourage whistleblower reporting.Fried Frank