Allianz case questions if DOJ encouraging scapegoating in individual liability push


Is a new Department of Justice (DOJ) policy focused on individual accountability for white-collar crime encouraging companies to scapegoat their employees? A recent court filing in a $6 billion corporate fraud case could give company officers some sleepless nights.

In September, the DOJ announced sweeping changes to its efforts to fight corporate crime, including new guidance regarding individual accountability, voluntary self-disclosure of violations, independent compliance monitors, and ways to strengthen and sharpen a firm’s compliance culture. Deputy Attorney General Lisa Monaco said then the agency would make individual accountability its No. 1 priority.

Claims made in federal court by a former portfolio manager at financial services firm Allianz Global Investors (AGI) could, if true, call into question the DOJ’s high ground on individual accountability. It could also serve as a cautionary tale.

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