A glimpse into the Department of Justice’s ethics and compliance operations

“We instill a culture of ethical conduct from the first day employees take the oath of office—an oath to well and faithfully execute the duties of their office,” Rosenstein said in a keynote address on FCPA Enforcement Developments on March 7. “Our Department’s name contains a moral value, and we reinforce it. We teach our employees what it means to stand for Justice.”

“But no organization with 115,000 employees is flawless,” Rosenstein said. “We maintain a culture of integrity, not merely a culture of trust. We do not assume that everyone will obey their oath. We rely on auxiliary precautions. We need mechanisms to correct mistakes and punish wrongdoers.”

The Justice Department’s Professional Responsibility Advisory Office “provides nationwide guidance about ethical responsibilities, and we designate experienced attorneys to serve as Professional Responsibility Officers in each U.S. Attorney’s Office. Everyone in the Department participates in annual ethics training.”

Rosenstein also talked about the Justice Department’s “professional, nonpartisan internal watchdogs. There are Offices of Professional Responsibility in Main Justice and in each of our law enforcement agencies, and an Office of the Inspector General with 475 employees and jurisdiction over the entire department.”

The Inspector General has criminal investigative authority, as well as administrative authority. “If an investigation requires criminal process, the Inspector General’s armed federal agents work with U.S. Attorneys to obtain grand jury subpoenas and search warrants, just like FBI agents,” he said. “Our internal watchdogs help us to deter waste, fraud, and abuse.

“Most importantly, Department of Justice employees develop the discipline imposed by the need to prove allegations to a judge and jury in an open courtroom, with credible witnesses and admissible evidence. That gives us a powerful incentive to seek the truth, and only the truth, wherever it may lead.”