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DOJ corporate enforcement overhaul: More declinations, fewer monitors, and FCPA enforcement still in question

On May 12, 2025, the U.S. Department of Justice (DOJ) announced revisions to key corporate criminal enforcement policies. The revisions’ stated aim is to provide more clarity and certainty of outcome to companies that...more

It’s the final countdown... for self-disclosure under DOJ’s amended Corporate Enforcement Policy

The recent amendment to the Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) of the Department of Justice’s (DOJ’s) Criminal Division expects companies to self-disclose allegations of misconduct within 120...more

Enforcement risks increase: DOJ and SDNY initiate self-disclosure pilot programs for individuals

In the past several years, the U.S. Department of Justice (DOJ) has been pursuing a variety of strategies to increase the number of corporate criminal prosecutions. As Assistant Attorney General Nicole Argentieri, chief of...more

DOJ announces policy for self-disclosures on criminal misconduct of acquired companies, with a catch

Deputy Attorney General Lisa Monaco announces a new safe harbor policy for voluntary self-disclosures of acquired entities’ criminal misconduct. Although the new safe harbor provides clear timelines for disclosure, the costs...more

The U.S. Department of Justice updates roadmap to an effective compliance program

On June 1, 2020, the U.S. Department of Justice (DOJ), Criminal Division, updated its guidance on the “Evaluation of Corporate Compliance Programs,” providing increased clarity on some of the key questions prosecutors will...more

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