News & Analysis as of

Cooperation Criminal Prosecution Corporate Counsel

Carlton Fields

DOJ Policy Changes Have Made Internal Investigations More Important Than Ever

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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

McDermott Will & Emery

DOJ Revamps Corporate Criminal Enforcement Policies with Continued Emphasis on Compliance

McDermott Will & Emery on

At a September 15, 2022, speech at New York University School of Law, US Deputy Attorney General (Deputy AG) Lisa Monaco announced several new policies intended to further the aggressive stance the US Department of Justice...more

Baker Donelson

Two Recent Corporate Pleas Affirm DOJ's Pledge to Crack Down on Criminal Enforcement

Baker Donelson on

Two recent criminal resolutions by the U.S. Department of Justice (DOJ) signal that DOJ is following through on Deputy Attorney General Lisa Monaco's recent pledge to crack down on corporate criminal enforcement....more

WilmerHale

Latin America Anti-Bribery Year-in-Review: 2019 Developments and Predictions for 2020

WilmerHale on

Foreign Corrupt Practices Act (FCPA) enforcement activity reached new heights in 2019. Corporate penalties paid to US enforcement agencies topped last year’s record levels, and individuals were charged at a pace matching last...more

WilmerHale

$1 Billion Ericsson Resolution, Three Jury Verdicts Cap Off Busy Fourth Quarter for US FCPA Enforcement

WilmerHale on

On December 6, 2019, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) agreed to resolve allegations that multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson or...more

The Volkov Law Group

Avanir Pharmaceuticals Pays More than $108 Million to Settle Kickback Violations

The Volkov Law Group on

Just to repeat myself – pharmaceutical and medical device firms face extraordinary risks of enforcement under the False Claims Act.  While everyone likes to write and focus on FCPA or anti-corruption risks for global drug and...more

Morrison & Foerster LLP

The UK’s Serious Fraud Office Issues Guidance for Corporate Cooperation

On 6 August 2019, the UK’s Serious Fraud Office (SFO) released Guidance on what it expects from organisations seeking cooperation credit in the agency’s investigations. The long-awaited Guidance is a codified and clarified...more

WilmerHale

Foreign Corrupt Practices Act Alert: Global Anti-Bribery Year-in-Review: 2018 Developments and Predictions for 2019

WilmerHale on

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

Holland & Knight LLP

Petrobras Agrees to Pay More Than $1.8 Billion for Facilitating FCPA Violations

Holland & Knight LLP on

• Four years ago, Brazilian authorities began Operation Car Wash, a wide-ranging and still ongoing corruption and money laundering investigation that has spanned 11 countries. • The fallout continues with a recent U.S....more

Latham & Watkins LLP

SEC Investigations: A Guide for Public Company Directors, Officers, and In-House Counsel

Latham & Watkins LLP on

Even public companies with a strong code of conduct, an exemplary tone at the top, robust internal controls, and a culture of compliance may face allegations of misconduct that can lead to an investigation by the Division of...more

McGuireWoods LLP

Expansion of FCPA “Pilot Program” is Good for Companies, but Heed the Fine Print

McGuireWoods LLP on

Deputy Attorney General Rod Rosenstein’s Nov. 29 announcement that the Department of Justice FCPA “Pilot Program” will be permanently expanded is good news for companies that repeatedly faced the dilemma of whether or not to...more

BCLP

DOJ’s “Half Off” Deals for Self-Reporting FCPA Misconduct: Certain Exclusions Apply, See Below for Details

BCLP on

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

WilmerHale

Global Anti-Bribery Year-in-Review: 2015 Developments and Predictions for 2016

WilmerHale on

I. Introduction: Enforcement Trends and Priorities - Among other significant developments, 2015 saw the U.S. Department of Justice (the “DOJ” or the “Department”) document a policy priority of holding individuals...more

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