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DOJ Updates Its Guidance on Corporate Compliance Programs, with an Emphasis on AI and Whistleblowers

The ECCP is intended to assist federal prosecutors in determining whether a corporation’s compliance program was effective at the time of the alleged offense(s) and, if not, what type of enforcement, monetary penalty, and...more

In Revised Corporate Enforcement Policy, DOJ Increases Incentives for Voluntary Self-Disclosure and Cooperation

On January 17, 2023, the Assistant Attorney General (AAG) for the Criminal Division of the U.S. Department of Justice (DOJ), Kenneth Polite, Jr., announced that DOJ had made “significant changes” to its Corporate Enforcement...more

Theranos: The Limits of the “Fake It Till You Make It” Strategy

In the case that tested the limits of the “fake it till you make it” approach to a startup business, on January 3, 2022, a jury in the U.S. District Court for the Northern District of California convicted Elizabeth Holmes,...more

U.S. Whistleblower Updates: Record Breaking Awards and a New FinCEN Whistleblower Program

The U.S. Securities and Exchange Commission (SEC) recently awarded approximately $36 million to a whistleblower who was culpable in the wrongful conduct and delayed reporting information to the agency for five years. The...more

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