On May 12, 2025, Matthew R. Galeotti — Head of the U.S. Department of Justice (DOJ) Criminal Division — issued an updated enforcement policy detailing the Criminal Division’s priorities for prosecuting corporate and...more
On February 10, 2025, President Trump signed an Executive Order (E.O.) directing a shift in the enforcement of the Foreign Corrupt Practices Act (FCPA). The order effectively pauses new FCPA investigations and enforcement...more
2/13/2025
/ Anti-Corruption ,
China ,
Compliance ,
Corporate Counsel ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Trump Administration
Pam Bondi was sworn into office as the United States Attorney General on February 5, 2025, and immediately issued a bevy of memoranda advancing the Trump Administration’s priorities. The memorandum entitled General Policy...more
2/11/2025
/ Attorney General ,
Cartels ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement ,
Enforcement Actions ,
Financial Crimes ,
Foreign Agents Registration Act (FARA) ,
Foreign Corrupt Practices Act (FCPA) ,
Sentencing ,
White Collar Crimes
Department of Justice (DOJ) Deputy Attorney General Lisa Monaco announced that the DOJ is adopting a whistleblower incentive program today at the American Bar Association’s 39th National Institute on White Collar Crime. In...more
5/10/2024
/ CFTC ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Federal Pilot Programs ,
FEPA ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
IRS ,
Penalties ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
The Department of Justice’s Criminal Division (DOJ) recently announced a Pilot Program on Voluntary Self-Disclosures for Individuals (the Individual VSD Pilot Program or Pilot Program), which allows certain individuals...more
In response to President Biden’s Executive Order authorizing increased data privacy measures, Assistant Attorney General (AAG) Matthew G. Olsen announced that the National Security Division of the Department of Justice (DOJ)...more
4/16/2024
/ Algorithms ,
Artificial Intelligence ,
Biden Administration ,
Compliance ,
Data Breach ,
Data Privacy ,
Data Protection ,
Data Security ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Enforcement ,
Executive Orders ,
National Security ,
Sensitive Personal Information ,
White Collar Crimes
Last year, on February 22, 2023, the Department of Justice (DOJ) announced a corporate Voluntary Self-Disclosure (VSD) policy, which is applicable to all U.S. Attorney’s Offices, setting nationwide incentives for voluntary...more
On February 22, 2023, the Department of Justice (“DOJ”) announced that all 93 United States Attorneys’ Offices throughout the country are implementing, effective immediately, a Voluntary Self-Disclosure Policy (“Policy”) for...more
On January 17, 2023, Assistant Attorney General (“AAG”) Kevin Polite announced revisions to the Department of Justice’s (“DOJ”) Corporate Enforcement Policy (“CEP”), which will apply to all corporate criminal matters. The...more
On January 1, 2021, Congress passed the National Defense Authorization Act for Fiscal Year 2021, an omnibus bill that includes the Anti-Money Laundering Act of 2020 (“AMLA”). The AMLA bans the use of anonymous shell companies...more
1/18/2021
/ Anti-Money Laundering ,
Anti-Retaliation Provisions ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Due Diligence ,
Enforcement Actions ,
Financial Institutions ,
FinCEN ,
Foreign Banks ,
Limited Liability Company (LLC) ,
Privately Held Corporations ,
Publicly-Traded Companies ,
Securities and Exchange Commission (SEC) ,
Shell Corporations ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury ,
Whistleblower Awards
DOJ Charges Two Men for Defrauding Federal Government Under the CARES Act -
Last week, the Department of Justice (“DOJ”) brought the first U.S. criminal action stemming from the federal coronavirus stimulus program. In...more
In a speech delivered on November 29, 2018, Deputy Attorney General Rod Rosenstein announced changes to the Justice Manual regarding cooperation credit for companies facing criminal and civil investigations.1 These changes...more
Last week, the Department of Justice (DOJ) issued the first report of its Cyber-Digital Task Force. The Task Force, which is comprised of several long-time DOJ officials, was tasked with distilling how the DOJ responds to...more
The Foreign Corrupt Practices Act (“FCPA”) prohibits both United States and foreign corporations and nationals from offering or paying, or authorizing the offer or payment, of anything of value to a foreign government...more
9/15/2016
/ Books & Records ,
Bribery ,
Cooperation ,
Corruption ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Internal Controls ,
Remediation ,
Self-Reporting ,
Voluntary Disclosure ,
White Collar Crimes ,
Yates Memorandum
Although the Yates Memo is now ten months old, senior executives and in-house counsel still do not have clarity about how the Department of Justice (“DOJ”) will apply the Memo’s principles to corporate investigations. On...more
7/15/2016
/ Cooperation ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Export Controls ,
False Claims Act (FCA) ,
Financial Services Industry ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Healthcare Fraud ,
Individual Accountability ,
Voluntary Disclosure ,
White Collar Crimes ,
Yates Memorandum