News & Analysis as of

Corporate Governance Self-Disclosure Requirements Anti-Corruption

NAVEX

Analyzing the U.S. Department of Justice’s New Whistleblower Rewards Programs and Revised Corporate Enforcement Policy

NAVEX on

The Department of Justice (DOJ) in recent weeks unveiled a newly created whistleblower rewards program within its Antitrust Division and an expanded whistleblower rewards program with the Criminal Division. The announcements...more

Redgrave LLP

Maintaining Information Preservation and Management Vigilance in an Age of Apparent Reduced Law Enforcement

Redgrave LLP on

Corporate legal departments are busy. They face new privacy regulations, ever-shifting trade policies, developments in artificial intelligence, and an unending stream of breaking news. It is difficult to keep up, and lately,...more

Morrison & Foerster LLP

DOJ Criminal Division Revises Its Corporate Enforcement Policy, Monitor Selection Policy, and Whistleblower Award Program

On May 12, 2025, the Criminal Division of the U.S. Department of Justice (DOJ) revised its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) and Corporate Whistleblower Awards Pilot Program (Whistleblower...more

DLA Piper

How Argentina Reached a Turning Point for Corporate Accountability and Compliance in 2024

DLA Piper on

In 2024, Argentina experienced a pivotal moment in corporate law enforcement with the first significant application of its Corporate Criminal Liability Law No. 27,401, enacted in 2018. This law holds private entities...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Launches Corporate Whistleblower Awards Pilot Program and Announces a New Incentive for Self-Reports

On August 1, 2024, the Department of Justice’s Criminal Division launched the Corporate Whistleblower Awards Pilot Program (the Program), following up on its announcement in March 2024 of a plan to offer whistleblower awards....more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Pilot Program Promises Non-Prosecution Agreements to Individuals Reporting Fraud, Bribery and Other Corporate Crimes

On April 15, 2024, the Department of Justice’s (DOJ’s) Criminal Division unveiled a new Pilot Program on Voluntary Self-Disclosures for Individuals that offers non-prosecution agreements (NPAs) to individuals who voluntarily...more

Foley Hoag LLP - White Collar Law &...

Anticorruption Enforcement and the Foreign Corrupt Practices Act: Trends to Track in 2024

This is the seventh in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more

A&O Shearman

What the U.S. Department of Justice’s new M&A safe harbor policy means for PE firms

A&O Shearman on

On October 5, 2023, Deputy Attorney General, Lisa Monaco, announced a new safe harbor policy for voluntary self-disclosures made in the mergers and acquisitions context. The safe harbor policy will apply Department-wide and...more

American Conference Institute (ACI)

[Event] 40th International Conference on the FCPA - November 28th - 30th, National Harbor, MD

Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investigations for Self-Disclosure Should Be Independent of DOJ To Avoid Fifth Amendment Issues

The Department of Justice (DOJ) has long encouraged companies to disclose to the DOJ potential violations of federal law, investigate themselves and report their findings in detail. The DOJ often depends on those self-reports...more

Foley Hoag LLP

CEP Revisions Incentivize “Extraordinary” Corporate Cooperation

Foley Hoag LLP on

Earlier in January 2023, the U.S. Department of Justice (DOJ) announced revisions to its Corporate Enforcement Policy (CEP) under the Foreign Corrupt Practices Act (FCPA) for the first time since 2017. In his speech...more

Morrison & Foerster LLP

In Revised Corporate Enforcement Policy, DOJ Increases Incentives for Voluntary Self-Disclosure and Cooperation

On January 17, 2023, the Assistant Attorney General (AAG) for the Criminal Division of the U.S. Department of Justice (DOJ), Kenneth Polite, Jr., announced that DOJ had made “significant changes” to its Corporate Enforcement...more

Foley Hoag LLP - Global Business and Human...

New FCPA Corporate Enforcement Policy Incentivizes Corporate Voluntary Self-Disclosure and Cooperation

Under the new FCPA Corporate Enforcement Policy recently released by the Department of Justice (“DOJ”), when a company has voluntarily self-disclosed misconduct, fully cooperated in the government’s ensuing investigation, and...more

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