All Things Investigations: Navigating New DOJ Directives - Declinations, Cooperation, and Whistleblower Programs with Mike DeBernardis and Katherine Taylor
Understanding the Latest DOJ Changes to Corporate Prosecutions
The Justice Insiders Podcast: Self-Disclosure, Cooperation, and the Hazards of Knowing Too Little
The Justice Insiders Podcast - AI-Washing: Everything Old Is New Again
Understanding the Whistleblower Pilot Program in the Southern District of New York
The Presumption of Innocence Podcast: Episode 30 - Why They Do It: Inside the Mind of a White Collar Criminal – A Discussion With Author Eugene Soltes
The Justice Insiders Podcast: Using External Resources for Internal Investigations
Encouraging and Managing Employee Self-Reporting
Keeping Up With the Bureau Episode 1: Overview of CFPB and State AG Initiatives/Expansion - The Consumer Finance Podcast
The Justice Insiders Podcast: The DOJ Wants You! - Part II: Voluntary Disclosures
The Justice Insiders: The DOJ Wants You!
JONES DAY TALKS®: CFTC and DOJ Target Derivatives Trading Across Industries
Compliance Perspectives: The Antitrust Division’s Office of Decree Enforcement
Do I Need a Lawyer? Federal Employees Under Investigation [More with McGlinchey Ep. 1]
Podcast: International Risks Facing Latin America Companies
Podcast - Risk Management: Revised FCPA Corporate Enforcement Policy
FCPA Compliance and Ethics Report-Episode 165-BHP FCPA Enforcement and Lessons Learned for the Compliance Practitioner
BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement
Episode 155-Mara Senn on FCPA Investigations and the Decision to Self-Disclose
Internal investigations have long been a valuable tool for companies and their executives to manage civil, regulatory, and criminal liability. By investigating potential corporate misconduct with the help of counsel, a...more
The Dutch Public Prosecution Office ("DPPO") has introduced a new policy (aanwijzing), effective 1 January 2025, outlining conditions and fine reductions for self-disclosure, cooperation and self-investigation in corporate...more
Federal prosecutors are exploring new ways to encourage business leaders to invest in their corporate compliance programs. Indeed, a Department of Justice official recently announced several new programs incentivizing...more
The Department of Justice (DOJ) has been making significant strides in emphasizing the importance of voluntary self-disclosure in corporate enforcement cases, particularly in the realm of the Foreign Corrupt Practices Act...more
2023 was a very active one for Department of Justice (DOJ or the “Department”) guidance, and that guidance had one clear theme: DOJ wants companies to voluntarily self-disclose their misconduct. To incentivize...more
On October 4, Deputy Attorney General (DAG) Lisa Monaco announced the Department of Justice’s (DOJ) new Safe Harbor Policy for voluntary self-disclosures made in connection with mergers and acquisitions (M&A). This policy is...more
On October 4, 2023, the U.S. Department of Justice (DOJ) announced a uniform approach for the resolution of voluntary self-disclosure (VSD) of misconduct discovered during M&A due diligence. The Mergers & Acquisitions Safe...more
Last September, US Deputy Attorney General Lisa Monaco issued a memorandum instructing the various departments in the Department of Justice to adopt a lenient enforcement policy toward corporations. The aim of this policy is...more
In late February, the United States Attorneys for the Southern and Eastern Districts of New York announced a new “Voluntary Self-Disclosure Policy” (VSD Policy), effective immediately, that applies to all United States...more
On February 22, 2023, the Department of Justice announced a new Voluntary Self-Disclosure Policy (the Disclosure Policy) that now governs corporate prosecutions by US Attorney’s Offices (USAOs) nationwide. Building on a 2022...more
On February 22, 2023, the United States Department of Justice (“DOJ”) issued the United States Attorney’s Offices’ Voluntary Self-Disclosure Policy (the “VSD Policy”) for corporate criminal enforcement, which sets forth the...more
Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors. In a speech at Georgetown University Law Center on...more
On January 17, 2023, Assistant Attorney General for the United States Department of Justice Kenneth A. Polite Jr. announced significant revisions to the Criminal Division’s Corporate Enforcement Policy (“CEP”). Four months...more
The U.S. Department of Justice (DOJ), through Assistant Attorney General Kenneth A. Polite Jr., announced on Jan. 17, 2023, "the first significant changes" to its Corporate Enforcement Policy (CEP) since 2017. The revisions...more
Previously, we introduced you to this topic and provided updates about the positive international trends in anti-corruption efforts, bribery, and the Organization for Economic Cooperation and Development (OECD). Today, we...more
Despite predictions of a slow-down in enforcement under the Trump administration—and indications that enforcement in some areas has decreased in the past year1—2018 was yet again an active year for FCPA enforcement. The year...more
Anti-Corruption enforcement remained a top priority in France, the UK, and the US in 2018. Join our firm's Global Anti-Corruption Team as they explain and analyze these three countries' anti-corruption enforcement efforts and...more
In a recently released letter, the Justice Department issued a declination to the Insurance Corporation of Barbados Limited (ICBL) for violations of the FCPA under the FCPA Corporate Enforcement Policy. DOJ required ICBL to...more
Today being the fortieth anniversary of the December 19, 1977 enactment of the Foreign Corrupt Practices Act (“FCPA”), we offer this Client Alert in celebration of the occasion. Fittingly, the U.S. Department of Justice...more
Yesterday I began an exploration of the General Cable Corporation (General Cable) Foreign Corrupt Practices Act (FCPA) enforcement action. It was settled with the DOJ via a Non-Prosecution Agreement (NPA) and the SEC via a...more
In a speech last week, Criminal Division Assistant Attorney General Leslie Caldwell touted the success of the FCPA Pilot Program. AAG Caldwell outlined the success of the FCPA enforcement program, listing many of the...more
The guidance issued by the DOJ in connection with the Pilot Program and recent declinations state that disclosure, remediation and cooperation are essential to any favorable resolution with the government. Six months...more
The Foreign Corrupt Practices Act (“FCPA”) prohibits both United States and foreign corporations and nationals from offering or paying, or authorizing the offer or payment, of anything of value to a foreign government...more
On April 5, 2016, the Fraud Section of the Department of Justice's (DOJ) Criminal Division issued an enforcement plan and guidance (the Guidance) laying out three steps it is taking to intensify Foreign Corrupt Practices Act...more
For the next year, the Justice Department may be offering up to a 50% discount on fines imposed in FCPA cases. Yesterday, the U.S. Department of Justice’s (“DOJ”) Criminal Division announced the launch of a one-year pilot...more