The U.S. Department of Justice crack-down on corporate crime began in the summer of 2002 with the collapse of the energy giant Enron. In the six years that have followed, more than 1300 senior corporate officials have been prosecuted. Some observers now believe this surge of white-collar prosecutions has run its course, except for the work of tracking down bad apples in the sub-prime mortgage mess.

Missing from this view is the much bigger and more fundamental story about the transition in federal business crime enforcement that has occurred over the past six years. The record numbers of prosecutions for foreign bribery, health care fraud, illegal hiring and other business activities that have occurred in recent years is a clear sign that something has changed. Another key indicator of this transition is the way business organizations are adapting, either voluntarily or involuntarily, to this new emphasis on enforcement. Corporations have been forced to spend multimillions on beefed-up compliance programs and internal investigations. It has become standard practice to self-disclose misconduct to DOJ officials. And to make matters even more challenging, the expectations and standards for “best in class” compliance and investigation procedures are steadily rising as prosecutors become more familiar with what corporations are doing to adapt to this new enforcement environment. //Read more