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Implementing Change in a Franchise System
Remember The Eugene Dietzgen Company? If you are under 40, you likely do not. Dietzgen was one of the world's largest makers of slide rules. But when was the last time you saw a slide rule? According to the Internet, the Dietzgen company is still around, but I suspect that it is a shadow of its former self.
And what about Howard Johnson's ice cream and restaurants? Back in the 1960s, HoJo ' as it was referred to ' was the premium ice cream chain. Today, there are a handful left, but what was at one time an industry leader has shrunk into near oblivion.
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The DOJ's Corporate Enforcement Policy: One Year Later
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.
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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.