After four years of decreased white collar enforcement activity, the Biden DOJ has announced several key policy changes designed to crack down on corporate misconduct: What companies need to know and how they can...more
New policy seeks to reduce the burden of navigating anti-corruption investigations and enforcement actions by multiple authorities.
The new DOJ policy seeks to increase coordination on FCPA and related anti-corruption...more
Increased international cooperation, more aggressive investigations and greater focus on individual accountability.
In light of the U.S. Supreme Court’s decision in Kokesh v. SEC, the SEC is expected to prioritize quicker,...more
Earlier this week, the U.S. Supreme Court resolved a circuit split among the Tenth and Eleventh Circuit Courts of Appeals by holding that because disgorgement in a Securities and Exchange Commission (SEC) enforcement action...more
6/9/2017
/ Disgorgement ,
Enforcement Actions ,
Financial Services Industry ,
Foreign Corrupt Practices Act (FCPA) ,
Investment Management ,
Kokesh v SEC ,
Misappropriation ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Statute of Limitations ,
White Collar Crimes
On April 5, 2016, the Department of Justice unveiled a one-year pilot program designed to encourage companies to self-report violations of the Foreign Corrupt Practices Act (the FCPA). Built upon the Department’s September 9,...more
4/15/2016
/ Bribery ,
Compliance ,
Cooperation ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Individual Accountability ,
Internal Investigations ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes ,
Yates Memorandum
On September 9, 2015, Deputy Attorney General Sally Quillian Yates introduced a new policy aimed at aggressively prosecuting individuals for white-collar crimes. A product of a DOJ working group that started under former...more