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The DoJ's view on what does—and doesn't—constitute meaningful cooperation

Joe Mont | September 28, 2016

The million-dollar question—often a multi-million dollar one—for companies to ask amid a civil law enforcement investigation or enforcement action: What does, and what does not, constitute meaningful cooperation?

During a speech this week at the Society of Corporate Compliance and Ethics’ annual conference in Chicago, Bill Baer, a principal deputy associate attorney general at the Department of Justice, offered fresh perspective on how his agency would answer that question. The bottom line: merely responding to a subpoena is hardly enough to claim meaningful cooperation.

As a backdrop for his comments, Baer reminded the audience of events leading up to the Great Recession, in particular systemic abuses by banks in the packaging and sale of residential mortgage backed securities. RMBS abuses “exposed a stunning breakdown in the ethics, the training, and the in-house compliance efforts of financial institutions here and around the world.”

For years the financial...

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