Compliance Perspectives: Compliance Challenges in India
FCPA Compliance Report-Episode 350, Linda Justice and Her Nancy Drew Approach
Day 16 of One Month to More Effective Continuous Improvement-Voluntary Monitoring
Day 5 of One Month to Better Investigations and Reporting-the Board’s Investigation Protocol
This article recaps Department of Justice guidance since the Trump Administration took office in January. These are topics we’ve addressed in previous articles and alerts, and are presented here in summarized form....more
On February 10, 2025, the president signed an executive order that paused investigation and enforcement of the FCPA for a period of 180 days, required the DOJ to review any existing FCPA investigation or prosecution, and to...more
On October 28, 2021, Deputy Attorney General Lisa Monaco announced revised Department of Justice (DOJ) guidance on corporate monitors. Going forward, prosecutors are free to require the imposition of a corporate monitor when...more
The Department of Justice (DOJ) has once again raised the bar for corporations seeking cooperation credit in government investigations. Last Thursday, DOJ issued a department memorandum and announced three significant...more
The first 100 days of President Biden's administration, not least its appointments to key leadership positions, suggest that it will investigate and pursue white collar cases much more aggressively than the Trump...more
Under the Biden Administration, we expect the Department of Justice to reinvigorate the policies aimed at increasing coordination between the criminal and civil divisions. In a 2015 Memorandum – the “Yates Memo” – former...more
On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more
Guidance sets out the SFO’s expectations for investigations but leaves open questions, particularly for cross-border investigations. On 6 August 2019, the UK Serious Fraud Office (SFO) issued its much-anticipated Corporate...more
In a recent decision that could have critical implications for corporate internal investigations conducted pursuant to a government agency’s request, the Southern District of New York expressed concern with the government’s...more
In a shift in policy, Deputy Attorney General Rod Rosenstein announced on November 29, 2018, that the DOJ would relax certain policies, dating back to 2015...more
In a speech delivered on November 29, 2018, Deputy Attorney General Rod Rosenstein announced changes to the Justice Manual regarding cooperation credit for companies facing criminal and civil investigations.1 These changes...more
On Thursday, November 29th, the U.S. Department of Justice (DOJ) announced changes to its policy known as the “Yates Memo.” That policy, established in 2015 by then-Deputy Attorney General Sally Yates, had required companies...more
Government attorneys now have additional discretion in False Claims Act (FCA) civil cases to award cooperation credit to a corporation that meaningfully assists the government’s investigation without necessarily identifying...more
In a speech delivered on Thursday, Nov. 29, 2018, Deputy Attorney General Rod Rosenstein described important changes to DOJ policies for awarding cooperation credit in corporate investigations. These changes have been...more
In 2017, the U.S. Department of Justice (DOJ) initiated a review of its 2015 policy concerning individual accountability in corporate cases (known as the "Yates Memo"). In the course of that review, the DOJ considered...more
There are multiple areas in the Department of Justice’s Evaluation of Corporate Compliance Programs which intersect with the area of continuous improvement. In addition to Prong 9. Continuous Improvement, Periodic Testing and...more
Many companies have an investigation protocol in place when a potential Foreign Corruption Practices Act (FCPA) or other legal issue arises? However, many Boards of Directors do not have the same rigor when it comes to an...more
The U.S. Department of Justice (DOJ) recently issued a memorandum ("The Yates memo") on September 9, 2015 by Deputy Attorney General Sally Yates, reaffirming the Government's commitment to prosecuting individuals. Say...more
Responding to criticism stemming from a lack of individual prosecutions as a result of the financial crisis, Deputy Attorney General Sally Yates has issued a new guidance memorandum establishing six new steps for federal...more
On September 9, 2015, Deputy Attorney General Sally Quillian Yates introduced a new policy aimed at aggressively prosecuting individuals for white-collar crimes. A product of a DOJ working group that started under former...more
On September 9, 2015, Deputy Attorney General Sally Yates of the United States Department of Justice (“DOJ” or the “Department”) issued a new policy memorandum (the “Yates Memo”) entitled “Individual Accountability for...more
On September 9, 2015, the Department of Justice (the Department) publicly announced that it had issued guidance to its criminal and civil prosecutors that purports to change, at least in part, the Department’s approach to...more