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Focus, Fairness, & Efficiency: DOJ White Collar Policy Shifts Signal Recalibration, But Not Revolution in Enforcement

On May 12, 2025, the Criminal Division of the U.S. Department of Justice (“DOJ” or the “Department”) issued a series of significant policy changes outlining the Trump administration’s new approach to white-collar enforcement....more

Whistleblowers Wanted: Proliferation of DOJ Whistleblower Policies Invites Harmonization by the Trump Administration

As Donald J. Trump prepares to begin his second presidential administration on January 20, 2025, many Department of Justice (“DOJ”) priorities and policies are likely to change. One new Biden administration initiative that is...more

[CLE Hybrid Event] To Self-Report or Not to Self-Report: DOJ's New ‘Safe Harbor’ Policy Tries to Answer the Question for M&A Cases...

It is one of the hardest questions a company can face: after discovering criminal conduct inside your company, do you self-report to the government or not? The reality is that when faced with the question of self-reporting,...more

To Self-Report or Not to Self-Report: With New M&A Safe Harbor Policy, DOJ Tries to Answer the Question

It is one of the hardest questions a company can face: after discovering criminal conduct inside your company, do you self-report to the government or not? If you can quickly and quietly fix the problem, then you may be able...more

Holiday Jeers: How The Grinch at DOJ May Make It Harder for Companies to Stay on the Nice List This Christmas

With the holiday season upon us, companies waiting for a nice surprise this Christmas are more likely to find a lump of coal in their stocking. In a series of recent announcements, Department of Justice (“DOJ”) officials have...more

Why Voluntary Independent Compliance Monitorships Are Growing in Popularity

When companies get into trouble, it’s common practice for the government to call on independent third parties to help clean up the mess. Companies under investigation by the Department of Justice (“DOJ”) often agree to...more

New CFTC Compliance Guidance Echoes Approach By Other Agencies

On September 10, 2020, the Commodity Futures Trading Commission (“CFTC”) Division of Enforcement released its long-awaited “Guidance on Evaluating Compliance Programs in Connection with Enforcement Matters,” which will be...more

DOJ Updates Its Guidance On Corporate Compliance Programs

In a little-noticed move yesterday, the U.S. Department of Justice (“DOJ” or “Department”) quietly amended its most important guidance document on corporate compliance. While the updates are far from a dramatic overhaul, they...more

Little “New” in SFO’s New Guidance on Compliance Programs

On January 17, 2020, the United Kingdom’s Serious Fraud Office (“SFO”) published new guidance regarding how the office assesses the compliance programs of organizations that are under investigation. “Evaluating a Compliance...more

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