On February 10, 2025, President Donald Trump signed an Executive Order directing the Department of Justice (DOJ) to pause enforcement of the U.S. Foreign Corrupt Practices Act (FCPA), citing concerns over the competitive...more
DOJ launches new initiative that promises to use the False Claims Act to combat cybersecurity threats by targeting government contractors who knowingly fail to comply with cybersecurity protocols.
The Civil Cyber-Fraud...more
10/26/2021
/ Cybersecurity ,
Cybersecurity Maturity Model Certification (CMMC) ,
Department of Justice (DOJ) ,
Executive Orders ,
False Claims Act (FCA) ,
Federal Contractors ,
Federal Grants ,
Fraud ,
Joe Biden ,
Popular ,
Safeguards Rule ,
Whistleblower Protection Policies
Updated DOJ Guidance calls on corporations to devote additional resources and attention to detect and prevent misconduct.
A well-structured and effective compliance program must evolve with lessons learned, be understood...more
Sellers of materials designated as “scarce,” whether directly or indirectly, should carefully monitor the rapidly changing federal and state landscape to avoid crossing the line between profit and price gouging.
“Price...more
Companies must now address three questions proactively.
On April 30, 2019, the DOJ’s Criminal Division issued updated guidance on how it will evaluate corporate compliance programs in its charging decisions going forward....more
5/14/2019
/ Chief Compliance Officers ,
Compliance ,
Corporate Culture ,
Corporate Governance ,
Corporate Management ,
Department of Justice (DOJ) ,
Employee Training ,
Guidance Update ,
Internal Controls ,
Risk Assessment ,
Risk Management ,
Third-Party Risk ,
Training ,
Whistleblower Protection Policies ,
Whistleblowers
Speaking at FCPA event, Rosenstein sets out adjustments to Yates Memo.
DOJ is modifying its focus on individual accountability in government investigations to substantially culpable individuals....more
Continuing its efforts to deter the use of real estate as a vehicle to launder proceeds of criminal activity, the Financial Crimes Enforcement Network (FinCEN) recently announced its plan to extend the reach and time frame of...more
8/22/2016
/ Anti-Money Laundering ,
Cash Transactions ,
Compliance ,
Customer Due Diligence (CDD) ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
FinCEN ,
Geographic Targeting Order ,
Real Estate Market ,
Shell Corporations ,
Title Insurance ,
Transparency
On April 5, 2016, the Department of Justice unveiled a one-year pilot program designed to encourage companies to self-report violations of the Foreign Corrupt Practices Act (the FCPA). Built upon the Department’s September 9,...more
4/15/2016
/ Bribery ,
Compliance ,
Cooperation ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Individual Accountability ,
Internal Investigations ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes ,
Yates Memorandum
A leak of 11.5 million documents from a law firm in Panama may implicate politicians, criminals, and celebrities in sheltering of fortunes in offshore tax havens through the use of shell companies. Called the “Panama Papers,”...more
On September 9, 2015, Deputy Attorney General Sally Quillian Yates introduced a new policy aimed at aggressively prosecuting individuals for white-collar crimes. A product of a DOJ working group that started under former...more