Corporate criminal defendants' pose unique sentencing problems. 2 Courts and
commentators have struggled with sentencing these statutory entities that have" no soul to …

In response to the broad scope of the Enron-era frauds, the federal government has adopted
novel strategies to manage the complexity of corporate criminal investigations. Chief among …

Deferred prosecution agreements (DPAs) and non-prosecution agreements (NPAs) are
proliferating. In the four years between 2002 and 2005, prosecutors and major corporations …

Substituting civil sanctions for criminal prosecution hen the federal grand jury subpoena
arrives and the first news stories appear that indicate a company employee is involved in a …

The doctrine of corporate criminal liability provides prosecutors with a powerful tool with
which to hold corporations criminally responsible for the criminal conduct of their employees …

We live in an age when prosecutors are a significant source of corporate regulation. The
terms of NPAs, DPAs, and state settlement agreements abound with regulations that go far …

According to a July 2015 Department of Justice (" DOJ") Report, federal prosecution of white-
collar crimes has hit a twenty-year low.'Rather than prosecuting individual corporate …

" DPAs [(Deferred Prosecution Agreements)] have had a truly transformative effect on
particular companies and, more generally, on corporate culture across the globe," declared …

Who should police corporate misconduct and how should it be policed? In recent years, the
Department of Justice has resolved investigations of dozens of Fortune 500 companies via …

In 1984, Congress created the United States Sentencing Commission to promulgate criminal
sentencing guidelines for the federal courts. 1 The first task of the Commission was the …