News & Analysis as of

Corporate Counsel Cooperation

Womble Bond Dickinson

The ICO’s Penalty Against 23andMe Brings New Emphasis on Cybersecurity Risks - Key Takeaways for U.S. Companies

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The dramatic increase in global reach that the internet provides U.S.-based companies comes as a double edge sword. While it significantly increases a company’s potential customer pool, it also subjects companies to...more

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

Latham & Watkins LLP

Key Takeaways From the SFO’s New Corporate Guidance

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The updated guidance puts a heavy emphasis on self-reporting and clarifies how corporates under investigation can earn cooperation credit from UK prosecutors....more

BakerHostetler

7 More US Attorneys’ Offices Issue Whistleblower Non-Prosecution Pilot Programs

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There was a flurry of DOJ whistleblower program activity over the last two weeks as the U.S. Attorneys’ Offices for the Eastern District of New York (EDNY Program), District of New Jersey (DNJ Program), Southern District of...more

BCLP

CFTC’s Annual Enforcement Results: Another Blockbuster Year

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The Commodity Futures Trading Commission ("CFTC") recently released its enforcement results for Fiscal Year 2023 ("FY 2023"), which ran from October 1, 2022, through September 30, 2023. ...more

Cooley LLP

UK Government Sets Out Approach to AI Regulation

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On Tuesday, 6 February 2024, the UK government released its consultation response to its March 2023 white paper titled ‘A pro-innovation approach to AI regulation’. The response provides further details on the UK government’s...more

BakerHostetler

SDNY Launches Whistleblower Program Aimed at Curbing Corporate and Public Corruption Crimes

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The newly announced whistleblower policy gives certain individuals who promptly and completely cooperate with prosecutors the opportunity to receive a non-prosecution agreement in exchange for their information....more

White & Case LLP

A View from Abroad: Unpacking DOJ’s M&A Safe Harbor Policy, Part II

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On October 4, 2023, United States Deputy Attorney General (DAG) Lisa Monaco announced a new Department of Justice (DOJ) Mergers & Acquisitions Safe Harbor policy that encourages companies to self-disclose criminal misconduct...more

Holland & Knight LLP

Cooperation with SEC: Yielding More Benefits, but Lack of Predictability Remains

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Although the SEC has long adhered to its Seaboard Report of Investigation to outline the analytical framework for the agency's cooperation program for companies, the exact benefits of self-policing, self-reporting,...more

WilmerHale

DOJ Announces Updates to Corporate Enforcement Policy

WilmerHale on

Assistant Attorney General Kenneth A. Polite, Jr. Announces Changes to Department of Justice Criminal Division’s Corporate Enforcement Policy - On January 17, 2023, Assistant Attorney General for the Criminal Division...more

Butler Snow LLP

Company Cooperation Leads to Criminal Discovery

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When a company discovers that a crime may have been committed by individuals within the company, or is alerted by the government of that possibility, the company will often hire an outside law firm to conduct an internal...more

McDermott Will & Schulte

DOJ Revamps Corporate Criminal Enforcement Policies with Continued Emphasis on Compliance

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

Health Care Compliance Association (HCCA)

[Event] Regional Healthcare Compliance Conference - January 28th, Orlando, FL

Looking for compliance training and networking in your area? HCCA’s Regional Healthcare Compliance Conferences offer practitioners convenient, local compliance training, including updates on the latest news in regulatory...more

WilmerHale

Latin America Anti-Bribery Year-in-Review: 2020 Developments and Predictions for 2021

WilmerHale on

Despite the impacts of the COVID-19 pandemic, 2020 was an active year for Foreign Corrupt Practices Act (FCPA) enforcement - and anti-corruption enforcement more generally. Enforcement actions related to Latin America played...more

Health Care Compliance Association (HCCA)

[Virtual Event] 2020 Virtual Regional Healthcare Compliance Conference - Honolulu, HI - October 8th - 9th, 8:25 am - 1:30 pm HST

Our Virtual Regional Healthcare Compliance Conferences provide updates on the latest news in regulatory requirement, compliance enforcement, and strategies to develop effective compliance programs. Watch, listen, and ask...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

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

WilmerHale on

Enforcement activity reached new heights in 2019. The year saw the two largest corporate resolutions in the history of the FCPA, corporate penalties paid to US enforcement agencies topped last year’s record levels, and...more

Jones Day

DOJ Policy Increases Incentives for Self-Reporting of Potentially Willful Trade Violations

Jones Day on

The Situation: The U.S. Department of Justice ("DOJ") has issued guidance revising its 2016 voluntary disclosure policy to provide companies stronger incentives to voluntarily self-report apparent potentially willful trade...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

Faegre Drinker Biddle & Reath LLP

Important New Guidance for Companies Considering Voluntary Disclosures of Export Control and Sanctions Violations

On December 13, 2019, the U.S. Department of Justice’s National Security Division (NSD) issued important new policy guidance regarding voluntary disclosures of export control and sanctions laws violations. Among other things,...more

Eversheds Sutherland (US) LLP

DOJ revises FCPA corporate enforcement policy to clarify self-disclosure and cooperation credit requirements

On November 20, 2019, the US Department of Justice (DOJ) announced the latest revisions to the Foreign Corrupt Practices Act Corporate Enforcement Policy (the Corporate Enforcement Policy). The revised language provides...more

BCLP

DOJ Further Incentivizes Voluntary Disclosure with Small Changes to FCPA Corporate Enforcement Policy

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The Department of Justice tweaked its FCPA Corporate Enforcement Policy to further incentivize corporations to make voluntary disclosures. These small changes essentially acknowledge that companies in a very early stage of an...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

Top 10 International Anti-Corruption Developments for August 2019

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

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