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Corporate Counsel › Internal Investigations › Voluntary Disclosure

Carlton Fields

DOJ Policy Changes Have Made Internal Investigations More Important Than Ever

Carlton Fields on

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

Holland & Knight LLP

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

Holland & Knight LLP on

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

Goodwin

Conducting Internal Investigations: In-House Counsel’s Guide

Goodwin on

Whether you are a director, or a member of an in-house legal, human resources, or internal audit team, there are sensitive scenarios that occur daily in companies and charitable organizations across industries that trigger...more

Faegre Drinker Biddle & Reath LLP

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

Faegre Drinker Biddle & Reath LLP on

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

BCLP

What is the Price for Failing to Voluntarily Disclose an FCPA Violation? – A Curious Case Of Successor Liability

BCLP on

On January 6, 2017, the Securities and Enforcement Commission filed an Administrative Action announcing a settlement with two global agribusiness companies. The Order is brief and short on facts. ...more

Thomas Fox - Compliance Evangelist

General Cable FCPA Enforcement Action – Part II: The Comeback

Thomas Fox - Compliance Evangelist on

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

Troutman Pepper Locke

Lessons Learned from the FCPA Pilot Program's First Six Months

Troutman Pepper Locke on

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 Volkov Law Group

Analogic FCPA Settlement – From Russia With(out) Love

The Volkov Law Group on

BK Medical, a subsidiary of the Denmark company, Analogic settled an FCPA enforcement action last week with the Justice Department and the SEC for approximately $14 million. Analogic agreed to pay $3.4 million to the Justice...more

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