Kamil Shields, a partner in Sullivan & Cromwell’s Litigation Group, discussed increased scrutiny by the DOJ to hold culpable individuals within an organization accountable. She anticipates more high-profile prosecutions of these individuals, given the DOJ’s rewards-based system that encourages corporate cooperation.
“You’re going to see, and I’ve already gotten a sense of, more of a focus on identifying who is culpable within an organization, and the expectation that a company is going to disclose those individuals to the department,” she said.
Read: “DOJ’s White Collar Developments to Watch in 2024.”