News & Analysis as of

Corporate Governance Enforcement Actions Deferred Prosecution Agreements

Womble Bond Dickinson

Can a Whistleblower Derail a Deferred Prosecution Agreement?

Womble Bond Dickinson on

A recent whistleblower suit could impact a company’s deferred prosecution agreement (“DPA”) potentially leading to further investigation by DOJ and additional penalties. A whistleblower suit was recently filed in the New...more

Paul Hastings LLP

Bigger Carrots, More Sticks? DOJ Revises Its Corporate Criminal Enforcement Policy

Paul Hastings LLP on

On January 17, 2023, Assistant Attorney General Kenneth A. Polite, Jr. (“AAG Polite”) announced several key revisions to the Department of Justice (“DOJ”) Criminal Division’s Corporate Enforcement Policy (the “CEP”) governing...more

Vinson & Elkins LLP

DOJ Chooses Sticks Over Carrots: Three Reasons Why Changes to DOJ’s Corporate Enforcement Policy May Chill Cooperation by...

Vinson & Elkins LLP on

In announcing recent changes to its corporate criminal enforcement policies, the Department of Justice (“DOJ” or the “Department”) continued its forceful “tough on crime” initiatives to deter wrongdoing....more

The Volkov Law Group

Watching the River Flow: The Evolution and Future of Compliance (Part I of III)

The Volkov Law Group on

Bob Dylan, Watch the River FlowI have to admit it – I still love to listen to Bob Dylan.  With age, his lyrics resonate more and more.  HERE is a nice version of Watch the River Flow in case you want to listen while reading...more

The Volkov Law Group

AML Compliance Lessons Learned from US Bancorp and Rabobank Enforcement Actions

The Volkov Law Group on

Global banks have been the focus of enforcement actions, focusing on AML and sanctions violations.  With the new beneficial ownership regulations effective May 11, 2018, we are about to see a significant transformation in AML...more

Thomas Fox - Compliance Evangelist

Using Strategic Risk to Your Advantage

I am beginning to feel this week’s theme becoming all-encompassing. As hard as I might try, it looks like it will be the Houston Astros second World Series appearance. During the first one back in 2005, I was in the corporate...more

Troutman Pepper

Executives Beware: The DOJ and SEC Have Set Their Sights on Individual Wrongdoing

Troutman Pepper on

The DOJ’s Yates Memo makes individual prosecutions a higher priority and makes a company’s own identification of potentially culpable individuals an explicit factor in assessing cooperation credit....more

NAVEX

The Future of U.K. Enforcement of Financial Crimes: Four Clues for 2015

NAVEX on

The legal and compliance landscape is changing quickly—it’s up to organisations that do business in the U.K. to strengthen their compliance programmes to meet these new challenges. In this whitepaper, Andrew Foose, vice...more

Morrison & Foerster LLP

Top Ten International Anti-Corruption Developments for February 2015

This installment of MoFo’s Top Ten International Anti-Corruption Developments highlights a number of significant domestic and global anti-corruption enforcement developments for busy in-house counsel and compliance...more

Thomas Fox - Compliance Evangelist

The Positive Effects of DPAs and NPAs in FCPA Enforcement

One of the oft-made criticisms regarding the Department of Justice (DOJ) around its enforcement of the Foreign Corrupt Practices Act (FCPA) is its the use of Deferred Prosecution Agreements (DPAs) and Non-Prosecution...more

Allen Matkins

Federal Prosecutors: The New Architects Of Corporate Governance

Allen Matkins on

If I asked who or what are the primary sources of corporate governance changes, I would expect the following answers: Congress, the Securities and Exchange Commission, the stock exchanges, proxy advisory firms, public pension...more

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