On February 22, 2023, the US Department of Justice issued a nationwide policy for all US Attorney’s Offices (USAOs) outlining the circumstances in which a company may receive credit for voluntary self-disclosure (VSD)....more
As we all respond to COVID-19 (the coronavirus), we should keep an eye on the responsive measures being taken by the US Department of Justice (DOJ), and consider how those measures might impact companies and individuals...more
On February 26, 2020, the US District Court for the District of Connecticut reinforced the Second Circuit’s recent decision to limit prosecutors’ ability to pursue Foreign Corrupt Practices Act (FCPA) charges against foreign...more
3/4/2020
/ Acquittals ,
Agency Relationship ,
Alstom ,
Bribery ,
Criminal Convictions ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
Indictments ,
Jurisdiction ,
Money Laundering ,
Securities and Exchange Commission (SEC) ,
Subsidiaries
The US Department of Justice (DOJ) is increasingly using the money laundering statute to prosecute individuals in corruption and bribery cases. The Foreign Corrupt Practices Act (FCPA) is the primary statute prohibiting...more
11/12/2019
/ Alstom ,
Bribery ,
Corporate Misconduct ,
Criminal Conspiracy ,
Department of Justice (DOJ) ,
Equador ,
Extortion ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Forfeiture ,
Indictments ,
Money Laundering ,
Money Laundering Control Act (MLCA) of 1986 ,
Venezuela ,
Willful Misconduct
Last week, the US Department of Justice (DOJ) released its updated guidance on how prosecutors should evaluate corporate compliance programs. The revised guidance reiterates and expands on the hallmarks of successful...more
On March 6, 2019, Mobile TeleSystems PJSC (MTS) consented to pay an $850 million sanction—the largest Foreign Corrupt Practices Act (FCPA) criminal penalty ever paid to the United States—and to a three-year monitorship to...more
On November 29, 2018, the US Department of Justice (DOJ) modified prior guidance on individual liability for corporate misconduct by affording federal prosecutors discretion to focus on “individuals who play significant roles...more
On October 12, 2018, Brian Benczkowski, Assistant Attorney General for the Criminal Division of the United States Department of Justice (DOJ), announced the “Selection of Monitors in Criminal Division Matters” memorandum (the...more
On August 24, 2018, the US Court of Appeals for the Second Circuit in United States v. Hoskins rejected the government’s broad reading of the Foreign Corrupt Practices Act (FCPA) and ruled that a foreign national without ties...more
On August 8, 2017, a three-judge panel of the US Court of Appeals for the Seventh Circuit unanimously upheld the first-ever criminal conviction of a New Jersey futures trader for the manipulative trading practice known as...more
8/14/2017
/ Appeals ,
Commodities ,
Constitutional Challenges ,
Criminal Convictions ,
Department of Justice (DOJ) ,
Dodd-Frank ,
High Frequency Trading ,
Indictments ,
Market Manipulation ,
Securities and Exchange Commission (SEC) ,
Spoofing