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
Building an effective post-pandemic compliance program requires taking stock of, and acting on, US regulators’ shifting approach and priorities.
As detailed in a recent Latham Client Alert, the US Department of Justice...more
Recent regulator statements and actions stress the need to empower compliance programs and officers and hold them accountable.
As companies navigate the post-pandemic environment, legal and compliance teams should take...more
The Strategy provides useful guidance for importers seeking to comply with the provisions of the UFLPA.
The Uyghur Forced Labor Prevention Act (UFLPA) was signed into law by President Biden on December 23, 2021, to...more
7/13/2022
/ Compliance ,
Customs and Border Protection ,
Due Diligence ,
Enforcement ,
Enforcement Priorities ,
Entity List ,
Forced Labor ,
Importers ,
Imports ,
New Guidance ,
Rebuttable Presumptions ,
Supply Chain ,
Uyghur Forced Labor Prevention Act (UFLPA)
The guidance provides insights for corporations seeking to develop and implement a best-in-class compliance program.
On June 1, 2020, the US Department of Justice (DOJ) issued updated guidance (Updated Guidance) regarding...more
The DOJ’s recently updated guidance poses helpful questions for UK corporates evaluating the effectiveness of their internal compliance programmes.
It is well known that a corporate’s failure to prevent offences can be...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