For the first time since its original publication in November 2012, on July 3, 2020, the U.S. Department of Justice (“DOJ”) Criminal Division and the U.S. Securities and Exchange Commission (“SEC”) published substantive...more
The COVID-19 pandemic presents novel challenges to U.S. regulators investigating allegations of corporate misconduct. Companies currently under investigation or that may find themselves under investigation must be prepared...more
Although uncertainty swirls around many aspects of the Coronavirus (COVID-19) crisis and its impact, in the world of white collar criminal enforcement, some certainties do exist: opportunities for fraud—against vulnerable...more
Last week the UK Serious Fraud Office (“SFO”) published its long-anticipated guidance on the steps companies should take when choosing to cooperate with the agency’s investigations. A mere five pages long, the SFO’s Corporate...more
Earlier this week, the Department of Justice issued “Guidelines for Taking Disclosure, Cooperation, and Remediation into Account in False Claims Act Matters” (the FCA Guidelines), intended to incentivize self-disclosure,...more
In a significant ruling by a federal judge in Manhattan late last week, the actions of a major law firm conducting an internal investigation on behalf of Deutsche Bank AG (“Deutsche Bank”) were deemed “fairly attributable” to...more
On Tuesday, April 30, 2019, the Department of Justice’s Criminal Division released an update (the “Update”) to the “Evaluation of Corporate Compliance Programs”1 first released by the Fraud Section in 2017. That document...more
As the annual ABA White Collar Crime Conference wrapped up in New Orleans last Friday night, the Department of Justice released the latest updates to its FCPA Corporate Enforcement Policy. The key changes to the policy...more
Last week, in what marked the first FCPA enforcement action of 2019, a federal grand jury in New Jersey returned an indictment against two former high-level executives—the president and chief legal officer—of Cognizant...more