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It happens every time we have a “recession” or economic turndown. But this time it is more daunting, not only given the severity of the economic situation, but also given the demographic realities. The talent crunch when the economy turns up and firms are hiring again will be magnified because so many Boomers are approaching the age when they will “retire” from current positions ' voluntarily or involuntarily.
In any case, they may be gone. And many are managers, firm and practice leaders as well as subject matter experts. Will there be enough people trained, experienced and ready to capably step into their shoes? How will the Boomers who want to stay be productively employed for mutual benefit?
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The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
This article discusses the practical and policy reasons for the use of DPAs and NPAs in white-collar criminal investigations, and considers the NDAA's new reporting provision and its relationship with other efforts to enhance transparency in DOJ decision-making.
The parameters set forth in the DOJ's memorandum have implications not only for the government's evaluation of compliance programs in the context of criminal charging decisions, but also for how defense counsel structure their conference-room advocacy seeking declinations or lesser sanctions in both criminal and civil investigations.
This article explores legal developments over the past year that may impact compliance officer personal liability.
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