Last week, a Hennepin County judge sentenced an employer following a first-of-its-kind criminal conviction for wage theft in Minnesota. Since its enactment in 2019, Minnesota’s Wage Theft Prevention Act has imposed stringent...more
The US Sentencing Guidelines permit reductions of criminal penalties based on a business organization’s inability to pay criminal fines, but were unclear about how it would make such determinations. An October 8 memorandum...more
The Situation: On October 8, 2019, the U.S. Department of Justice ("DOJ") announced two significant developments relating to the enforcement of white-collar crime: (i) new guidance on how prosecutors should evaluate requests...more
On October 8, 2019, the US Department of Justice (DOJ or Justice Department) issued new guidance on evaluating inability-to-pay arguments in a memorandum to the Criminal Division. The memorandum provides considerably more...more
On Tuesday, October 8, 2019, the Department of Justice provided guidance on how its prosecutors should evaluate claims of corporate poverty. This comes on the heels of Deputy Assistant Attorney General Matthew Miner’s...more
On September 12, 2019, Deputy Assistant Attorney General Matthew Miner signaled that the Department of Justice may provide further guidance to prosecutors—and companies—on how to evaluate claims of corporate poverty. In a...more