Karp and Mendelsohn: Is RBS the first enforcement action under DOJ policy against piling on?
On May 9 the DOJ announced a new policy concerning the coordination of penalties imposed by more than one regulator or law enforcement authority in corporate resolutions.
This new policy (pdf) against “piling on” requires DOJ attorneys to “coordinate with one another to avoid the unnecessary imposition of duplicative fines, penalties, and/or forfeiture against [a] company,” and further instructs DOJ personnel to “endeavor, as appropriate, to .… Continue Reading