It's now been over 100 days since Donald Trump was sworn in as the 45th President of the United States. While there is currently considerable debate in the press as to newly installed administration's accomplishments over this timeframe, there has never been any debate as to some of the strategies and stances it planned to pursue upon taking command of the White House.
A person needn't look further than the Department of Justice, as Attorney General Jeff Sessions has indicated from day one of his ascension to the role of the nation's top cop that the agency would be focusing primarily on violent crime and illegal immigration.
Indeed, Sessions' relentless vows to crack down on these two areas coupled with everything from President Trump's considerable global business holdings to the DOJ's recent hiring freeze in its Fraud Section led many observers to conclude that combating white collar crime would be a very low priority in the next four years.
Interestingly enough, however, the Attorney General gave a speech at the annual meeting of the Ethics and Compliance Initiative last week in which he reiterated the DOJ's commitment to combating corporate malfeasance.
Speaking to a gathering of attorneys tasked with ensuring their corporations remain above board, Sessions indicated that the actions of corrupt businesses will not go overlooked and reemphasized the DOJ's commitment to enforcing the Foreign Corrupt Practices Act.
“Companies should succeed because they provide superior products and services, not because they have paid off the right people,” said Sessions.
For those unfamiliar with the FCPA, it was originally passed back in 1977 and expressly outlawed corporations from securing business advantages through the payment of bribes to foreign officials.
The law became a favorite weapon of the Fraud Section in the mid 2000s, and has since become a major component of virtually all global business decisions and a target of many industry leaders. Indeed, President Trump voiced disdain for the anti-bribery act back in 2012, arguing that it placed U.S. business at a "huge disadvantage" abroad.
It's worth noting that while AG Sessions reinforced the DOJ's commitment to combating white collar crime, he indicated that the enforcement efforts would focus more on holding key players responsible for mismanagement than the corporations itself.
It will be interesting to see the extent to which the DOJ makes white collar crime a priority in the years ahead.
In the meantime, if you are under investigation or have been formally charged with any manner of white collar crime, it's imperative to consider speaking with a skilled legal professional as soon as possible as the stakes are simply too high.