Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors.
In a speech at Georgetown University Law Center on...more
2/7/2023
/ Bribery ,
Chief Compliance Officers ,
Compliance ,
Cooperation ,
Corporate Misconduct ,
Corruption ,
Declination ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Foreign Corrupt Practices Act (FCPA) ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes
Updated DOJ policies will continue to focus on individual accountability and corporate recidivism, while aiming to provide additional incentives for voluntary self-reporting, foster greater transparency on use of monitors,...more
9/28/2022
/ Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Misconduct ,
Corporate Officers ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
New Guidance ,
Personal Liability ,
Voluntary Disclosure
New enforcement advisory encourages reporting of foreign corrupt practices that the agency intends to pursue under the Commodity Exchange Act.
On March 6, 2019, the Division of Enforcement (Division) of the US Commodity...more
Ruling holds that the government cannot use conspiracy and accomplice liability theories to reach foreign nationals that lack US ties.
Key Points:
..Non-resident foreign nationals who are not otherwise subject to direct...more
The revised FCPA Corporate Enforcement Policy signals DOJ’s emphasis on corporate voluntary self-disclosure, rewarding cooperating companies with a presumption in favor of declination and reductions in penalties.
...more
The Guidance parallels the DOJ approach under the FCPA, but does not specify the value of mitigation and may create contradictory incentives.
The National Security Division (NSD) of the US Department of Justice (DOJ)...more
Doug Greenburg is a partner at Latham & Watkins and a Vice Chair of the global Litigation Department. His practice focuses on internal corporate investigations, white collar criminal defense, and US Securities and Exchange...more
FCPA Opinion Release provides insight into the jurisdictional reach of the FCPA and the level of due diligence the DOJ expects.
On November 7, 2014, the US Department of Justice (DOJ) issued its second and final...more
Foreign Corrupt Practices Act (FCPA) enforcement continues to be a priority for the United States Department of Justice (DOJ) and Securities and Exchange Commission (SEC). In recent years, U.S. authorities have aggressively...more
6/4/2014
/ Compliance ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Investigations ,
Investigations ,
Remediation ,
Risk Assessment ,
Risk Management ,
Securities and Exchange Commission (SEC)