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New Internal DOJ Guidance on Compensating Victims and Coordinating Corporate Penalties in Parallel Proceedings

On June 5, 2025, the Department of Justice (“DOJ”) directed prosecutors to prioritize compensating victims when resolving multiagency investigations involving corporate defendants. ...more

DOJ Announces White Collar Enforcement Priorities and Revisions to Related Policies

On May 12, 2025, Matthew Galeotti, the Head of the Criminal Division at the Department of Justice ("DOJ") issued a new white collar enforcement plan (“Enforcement Plan”) titled “Focus, Fairness, and Efficiency in the Fight...more

DOJ Rolls Out Corporate Whistleblower Pilot Program

On August 1, 2024, the Department of Justice officially launched a three-year pilot program to reward whistleblowers who report corporate misconduct....more

DOJ Criminal Division Announces Pilot Program on Voluntary Self-Disclosure for Individuals

On April 15, 2024, the Criminal Division of the Department of Justice (DOJ) announced the Pilot Program on Voluntary Self-Disclosure for Individuals, providing transparency regarding the circumstances in which Criminal...more

DOJ Announces Pilot Whistleblower Rewards Program and Increased AI Enforcement

On March 7, 2024, Deputy Attorney General Lisa Monaco announced Department of Justice (DOJ) initiatives to incentivize whistleblowers with payouts from civil or criminal forfeitures and to integrate artificial intelligence...more

United States V. Danske Bank: New Theory of Liability for Violation of US AML Standards

This Article discusses the recent plea agreement between the United States and Danske Bank. It argues that the Department of Justice has advanced a new and evolving theory of liability for foreign banks that access the U.S....more

DOJ Announces Significant Guidance on Compliance, Compensation, Communications and Cooperation

On March 3, 2023, as part of the rollout of several updates to its guidance on corporate compliance programs, the Department of Justice (DOJ) released a new policy aimed at incentivizing compliance-driven compensation and...more

Department of Justice Issues Voluntary Self-Disclosure Policy for Corporate Criminal Enforcement Applicable to U.S. Attorneys’...

On February 22, 2023, the Department of Justice (DOJ) issued a Voluntary Self-Disclosure Policy (VSDP) which, effective immediately, applies to all U.S. Attorneys’ Offices (USAOs) nationwide with respect to corporate criminal...more

The Corporate Crime Advisory Group Has Spoken: DOJ Revises Corporate Criminal Enforcement Policies

On September 15, 2022, the Department of Justice (Department) released a memorandum revising several key aspects of its corporate criminal enforcement policies. The new policy, titled Further Revisions to Corporate Criminal...more

A Look Ahead into Corporate Enforcement in the Biden Administration

Just one year after President Biden’s election, senior administration officials have signaled in public remarks that the federal government will amplify enforcement pressure on corporations and their employees through...more

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