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Curtis Discusses DOJ’s Approach to DPA Violations with GIR

June 20, 2024

Deborah Curtis, White Collar Defense & Investigations partner, was recently quoted in the Global Investigations Review article, “DOJ likely to impose guilty plea on Boeing for DPA violations, lawyers say.” The article discusses how the U.S. Department of Justice (DOJ) might approach Boeing’s breach of its 2021 deferred prosecution agreement (DPA). In a May 14 letter, the DOJ indicated the company had breached its DPA by failing to properly maintain its compliance program.

Curtis, who was previously responsible for overseeing all investigations and prosecutions of sanctions and export violations at DOJ, told Global Investigations Review that the DOJ’s response to the telecom company Ericsson’s breach of its DPA in 2021 could be an indication of how the agency may handle the Boeing settlement. After the DOJ found that Ericsson breached its DPA in 2021, the company had to pay $206 million, agree to an extra year of compliance monitoring, and plead guilty to a conspiracy charge under the Foreign Corrupt Practices Act to resolve the agency’s finding.

DOJ officials have publicly said that it will impose harsh sanctions on companies that break the law again and the agency could use this opportunity to drive its point home. “I think they could make an example of Boeing,” Curtis said.

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