12/17/19

17

Review

CORPORATE CRIMES

UNIVERSITY OF IOWA, COLLEGE OF LAW

Essay Question 1

In class, we listed the standard features of DPAs:

— Admission of facts underlying crime Corporate agreement to
continue to cooperate
— Fines and restitution
— Improve compliance; hire a monitor
— Waive statute of limitations
— Acknowledgment that if provisions breached, prosecution resumes
— Timeline for dropping charges for compliance
— Compliance reforms
Name one of the above that you think should not be standard or that
should be used in a different way or name a new feature you think
should be standard. Defend your answer using the terms and policy
objectives referenced in class.

Essay Question 2

SpyD Corp. offers private investigation services to customers who

want to find out details about someone’s (the “target’s”) identification.
They employ about 500 people, split into 50 divisions of ten people,
one for each state. Jules is a manager in one of the divisions. He
decides to use some target information (acquired by subverting SpyD’s
digital compliance protocols) to open credit cards in their names. He
then uses these credit cards for some personal expenses and to throw
a moral-boosting pizza parties for his coworkers. SpyD quickly
catches on, reports what happened to the government and fully
cooperates in the investigation. However, to maintain public
confidence in their services, SpyD insists on a public narrative that
pins all the blame on Jules.

You’re negotiating a DPA with a prosecutor. The prosecutor has asked

for your calculation of SpyD’s culpability score. How do you respond?

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Essay Question 3

Alice was a VP of sales at Wonderland Corp., a gardening

supply chain. Her forecasts projected that red roses would
be hot for the coming season. Her supplier, however, had
only white roses. In aggressive negotiations, the supplier
offered Alice a side cut of .5% of the sales price if she’d go
with white roses. Alice agreed. A check for $15k arrived to
her private address later that week. The next day, she
cashed it at a check-cashing service. After three deposits of
$5,000 on separate days to her checking account, she
bought a vintage red Camaro which she named “Rose.”

Assess any liability Alice may have for money laundering.