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Department of Justice Announces First-Ever Pilot Program on Compensation Incentives and Clawbacks, Revisions to Corporate Guidance...

On March 2, 2023, in remarks delivered at the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco announced a new policy creating incentives for companies to adopt...more

DOJ Issues Consolidated Guidance for False Claims Act Cooperation Credit

The United States Department of Justice this month released a revised and consolidated set of guidelines for determining cooperation credit for organizations facing exposure under the False Claims Act. The consolidated...more

Yates Memo in Action: No Cooperation Credit in FCPA Enforcement for Failing to Disclose Key Facts

A recent case illustrates both the ongoing corruption risks for U.S. companies doing business in developing countries such as China and the Government’s tougher stance on settling white collar crime cases. In this case, the...more

DOJ Foreshadows Future Certification Requirement for Businesses to Receive Cooperation Credit

Last fall, Deputy Attorney General Sally Yates announced (Yates memo) that the DOJ would require businesses to share all relevant facts about individuals when disclosing misconduct to be entitled to cooperation credit. The...more

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