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
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