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Compliance Self-Disclosure Requirements Corporate Misconduct

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Paul Hastings LLP

DOJ’s M&A Safe Harbor Highlights Importance of Post-Close Due Diligence and Integration

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On June 16, the U.S. Department of Justice’s (DOJ’s or Department’s) National Security Division (NSD or Division) announced they had declined to prosecute the private equity firm White Deer Management LLC for violations of...more

Foley & Lardner LLP

DOJ Criminal Division Updates (Part 3): New Reasons for Companies to Self-Disclose Criminal Conduct

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Share on Twitter Print Share by Email Share Back to top On May 12, 2025, the U.S. Department of Justice (DOJ) announced revisions to its Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP). (See...more

Thomas Fox - Compliance Evangelist

Compliance into the Weeds: USRA Declination Case Study - Self-Disclosure Best Practices

The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting...more

Alston & Bird

Enter the Matrix: CFTC’s New Framework for Self-Reporting, Cooperation, and Remediation

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Our White Collar, Government & Internal Investigations Group analyzes new enforcement guidance from the Commodity Futures Trading Commission (CFTC) that aims to incentivize self-reporting of potential violations....more

Health Care Compliance Association (HCCA)

Private-pay “crime stoppers”: Digesting the Corporate Whistleblower Awards Pilot Program

The U.S. Department of Justice’s (DOJ) Criminal Division launched its Corporate Whistleblower Awards Pilot Program (“Criminal Whistleblower Program”) in August of 2024 to encourage tips for various types of fraud, including...more

Mintz - Health Care Viewpoints

EnforceMintz – DOJ Policy Developments in 2024 Seek to Motivate More Voluntary Self-Disclosures

Over the past two years, the Department of Justice (DOJ or the Department) has actively incentivized companies to voluntarily self-disclose potential civil and criminal violations. For example, in 2023, in the criminal...more

Society of Corporate Compliance and Ethics...

Understanding the Latest DOJ Changes to Corporate Prosecutions

On November 22, 2024, then Principal Deputy Assistant Attorney General Nicole Argentieri recapped the changes made during the Biden Administration in enforcement policies and announced a few new ones. To better understand...more

Husch Blackwell LLP

The Justice Insiders Podcast: Self-Disclosure, Cooperation, and the Hazards of Knowing Too Little

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Host Gregg N. Sofer welcomes Husch Blackwell partner Catherine Hanaway to the podcast to discuss the recent sentencing of Nishad Singh, a former key lieutenant of Sam Bankman-Fried, the cryptocurrency mogul responsible for...more

Mitratech Holdings, Inc

5 Trends Shaping Whistleblower Regulations in 2025

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In 2025, whistleblower regulations are poised for major evolution, reflecting a renewed commitment to transparency and accountability. The Ethics and Compliance Initiative (ECI) 2023 survey revealed a startling statistic:...more

Guidepost Solutions LLC

Monitoring Against Whistleblower Retaliation

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Saves Lives, Prevents Major Crimes, and Accelerates Voluntary Self - Disclosures The U.S. Department of Justice (“DoJ”) recently spotlighted its Whistleblower Awards Program and Voluntary Self Disclosure (“VSDs”)...more

Bracewell LLP

Keeping an Eye on AI: DOJ Updates its Playbook for Corporate Compliance

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On September 23, 2024, Principal Deputy Assistant Attorney General Nicole Argentieri announced that the US Department of Justice (DOJ) had issued updated guidance to federal prosecutors in its “Evaluation of Corporate...more

The Volkov Law Group

Commerce Department Updated its Voluntary Self-Disclosure Policy for Export Controls Violations

The Volkov Law Group on

The Commerce Department’s Bureau of Industry and Security (“DOC-BIS”) is adopting procedures to generate voluntary self-disclosures for violations of export controls laws.  Companies have to weigh carefully the risks when...more

Foley & Lardner LLP

DOJ Stresses AI Risk and Whistleblower Protection in Revised Corporate Compliance Guidance

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On Monday, September 23, DOJ’s Criminal Division announced updates to its guidance for evaluating corporate compliance programs (“ECCP”). Principal Deputy Assistant Attorney General Nicole Argentieri also delivered remarks...more

The Volkov Law Group

DOJ Awards Declination to Proterial Cable America for Fraud — Proterial Pays $15.1 Million in Disgorgement

The Volkov Law Group on

DOJ is pushing hard for voluntary disclosures and urging companies to take advantage  of its Voluntary Disclosure Program.  The carrot is significant — a declination in exchange for cooperation, remediation and disgorgement....more

NAVEX

Whistleblower Awards Keep Adding New Compliance Pressures

NAVEX on

Whistleblower awards from regulatory agencies seldom make news in corporate compliance circles anymore, but two recent items from the world of whistleblower awards do deserve compliance officers’ attention. They’re a reminder...more

BCLP

DOJ Piles On the Incentives for Individuals to Blow the Whistle on Companies

BCLP on

Historically, successful white-collar prosecutions often turn on the government’s ability to identify “insiders” with firsthand knowledge of the alleged criminal scheme, who opt to cooperate with prosecutors in exchange for...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Launches Corporate Whistleblower Awards Pilot Program and Announces a New Incentive for Self-Reports

On August 1, 2024, the Department of Justice’s Criminal Division launched the Corporate Whistleblower Awards Pilot Program (the Program), following up on its announcement in March 2024 of a plan to offer whistleblower awards....more

Bracewell LLP

Creating an Army of In-House Investigators

Bracewell LLP on

In its never-ending war on corporate fraud, the Department of Justice (“DOJ”) has just commissioned a private army to fight as never before. On August 1, the DOJ launched a three-year program to provide financial rewards to...more

Lowenstein Sandler LLP

DOJ Says You Can Put the Fire Out From Inside the House: New Voluntary Self-Disclosure Program Seeks to Root Out Corporate Crime...

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Introduction: On April 15, 2024, the Department of Justice’s (DOJ) Criminal Division announced a new Pilot Program on Voluntary Self-Disclosure for Individuals. Under this program, individuals who voluntarily disclose certain...more

NAVEX

Navigating the DOJ’s New Pilot Program

NAVEX on

In a bold move, the U.S. Department of Justice (DOJ) launched a pilot program designed to encourage corporate executives to disclose information about financial misconduct within their organizations. Through this initiative,...more

Snell & Wilmer

The Department of Justice Offers Individual Corporate Wrongdoers a “Get Out of Jail Free Card” in New Voluntary Self-Disclosure...

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The Department of Justice’s Criminal Division (DOJ) recently announced a Pilot Program on Voluntary Self-Disclosures for Individuals (the Individual VSD Pilot Program or Pilot Program), which allows certain individuals...more

Mintz

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

Mintz on

Drawing on a carrot and stick approach, Department of Justice (“DOJ” or the “Department”) guidance in 2023 focused heavily on incentivizing companies to voluntarily self-disclose their misconduct. This guidance included the...more

Guidepost Solutions LLC

A “Quick Guide” to Government Whistleblower and Voluntary Self-Disclosure Programs: Heed the Warning from DOJ to Strengthen...

The Department of Justice (DOJ) has sounded the alarm: an aggressive crackdown on corporate misconduct is imminent. With an enforcement program on the horizon, corporations must heed the warning and take proactive measures to...more

BCLP

New DOJ Pilot Program Incentivizes Individuals to Report Criminal Conduct

BCLP on

Companies beware! The U.S. Department of Justice (DOJ) announced a pilot program “designed to encourage voluntary self-disclosure by individual participants in certain types of criminal conduct involving corporations.” In...more

Venable LLP

DOJ Announces Pilot Program for Individual Voluntary Self-Disclosures

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On April 15, 2024, the Department of Justice (DOJ) criminal division announced a new pilot program designed to reward individuals with non-prosecution agreements (NPAs) who voluntarily self-disclose "actionable, original...more

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