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Criminal Prosecution Cooperation

Patterson Belknap Webb & Tyler LLP

Second Circuit Rejects Challenge to Stratton Limits on Sentencing Enhancements

In United States v. Sterkaj, the Second Circuit (Cabranes, Raggi, and Nathan) vacated a sentence imposed on Klaudio Sterkaj because it represented an impermissible upward variance under United States v. Stratton, 820 F.2d 562...more

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

BakerHostetler

The DOJ Announces Administration’s Revised Corporate Enforcement Strategy

BakerHostetler on

On May 12, 2025, Matthew Galeotti, Head of the Department of Justice’s (DOJ) Criminal Division, unveiled a comprehensive white collar enforcement strategy titled “Focus, Fairness, and Efficiency in the Fight Against...more

Fenwick & West LLP

DOJ Announces Key Revisions to Corporate Enforcement and Voluntary Self-Disclosure Policy

Fenwick & West LLP on

On May 12, 2025, the Head of the Department of Justice’s (DOJ) Criminal Division, Matthew Galeotti, announced a new white collar enforcement plan in a memorandum entitled “Focus, Fairness, and Efficiency in the Fight Against...more

Society of Corporate Compliance and Ethics...

Understanding the Latest DOJ Changes to Corporate Prosecutions

On November 22, 2024, then Principal Deputy Assistant Attorney General Nicole Argentieri recapped the changes made during the Biden Administration in enforcement policies and announced a few new ones. To better understand...more

Husch Blackwell LLP

The Justice Insiders Podcast: Self-Disclosure, Cooperation, and the Hazards of Knowing Too Little

Husch Blackwell LLP on

Host Gregg N. Sofer welcomes Husch Blackwell partner Catherine Hanaway to the podcast to discuss the recent sentencing of Nishad Singh, a former key lieutenant of Sam Bankman-Fried, the cryptocurrency mogul responsible for...more

Katten Muchin Rosenman LLP

Chicago United States Attorney's Office Launches Pilot Program to Encourage Self-Disclosure

On September 16, the US Attorney's Office for the Northern District of Illinois (NDIL) announced the launch of its Individual Self-Disclosure (ISD) Pilot Program. The program offers non-prosecution agreements to qualifying...more

Skadden, Arps, Slate, Meagher & Flom LLP

Decoding AFA’s Guide: A Comparison of Sponsorship and Charitable Donations in France, the US and the UK

On March 26, 2024, the French Anti-Corruption Agency (AFA) published a guide on how to engage in corporate sponsorship and charitable donation activities while appropriately mitigating corruption risks (the Guide)...more

BakerHostetler

The Lines Are Open! DOJ Adds New Tool in Anticorruption Efforts With Whistleblower Pilot Program

BakerHostetler on

Building on the recent passage of the Foreign Extortion Prevention Act (FEPA), at the American Bar Association’s 2024 National Institute on White Collar Crime conference in San Francisco earlier this month (2024 ABA...more

BakerHostetler

DOJ to Corporations - “Knock on Our Door Before We Knock on Yours”

BakerHostetler on

At last week’s ABA National White Collar Crime Institute, the leadership of the Department of Justice (the DOJ or the Department), including Attorney General Merrick Garland and Deputy Attorney General Lisa Monaco, made clear...more

Allen Barron, Inc.

What is the IRS Offshore Voluntary Disclosure Program?

Allen Barron, Inc. on

What is the IRS Offshore Voluntary Disclosure Program and who is it designed to help? What are the guidelines for voluntary disclosure to the IRS and who is eligible to apply? The IRS Offshore Voluntary Disclosure...more

WilmerHale

Criminal Indictment for Medicare Advantage Fraud

WilmerHale on

The U.S. Department of Justice (DOJ) recently announced a rare criminal indictment involving the Medicare Advantage program—a contrast from DOJ’s more typical use of its civil enforcement authority to pursue similar issues...more

Troutman Pepper Locke

The Stick and the Carrot: DOJ Continues to Eye Corporate Crimes, While Encouraging Prompt Self-Disclosures of Misconduct...

Troutman Pepper Locke on

On October 4, Deputy Attorney General (DAG) Lisa Monaco announced the Department of Justice’s (DOJ) new Safe Harbor Policy for voluntary self-disclosures made in connection with mergers and acquisitions (M&A). This policy is...more

Foley Hoag LLP

DOJ Announces New Safe Harbor Policy for Self-Disclosures in Connection with M&A Transactions and Additional Resources for...

Foley Hoag LLP on

On October 4, 2023, the U.S. Department of Justice (“DOJ”) announced a new Mergers & Acquisitions (“M&A”) Safe Harbor Policy to further encourage self-disclosures and provide companies with additional predictability in the...more

Goodwin

DOJ Announces Safe Harbor Policy for M&A Self-Disclosures

Goodwin on

On October 4, 2023, the United States Department of Justice (DOJ) announced a “safe harbor” policy for companies that voluntary self-disclose violations identified during the M&A process. US Deputy Attorney General Lisa...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Compelled Interviews Admissible in Criminal Prosecution Against Former Company President and Its General Counsel

A New Jersey federal court has ruled that a company’s self-disclosure of potential Foreign Corrupt Practices Act (FCPA) violations did not render the company a state actor, allowing evidence obtained by its internal...more

Venable LLP

Honesty is Good for Your Bottom Line: Commerce, Treasury, and DOJ Tout the Benefits of Voluntary Self Disclosure in Tri-Seal...

Venable LLP on

Voluntary self-disclosure is a valuable remediation measure for companies who identify their own potential violations of U.S. sanctions, export controls, and other national security laws....more

Carlton Fields

Catching More Flies With Honey: Recent DOJ Policy Changes to Coax Cooperation From Corporate Defendants

Carlton Fields on

In March 2023, the Department of Justice announced two policy changes that attempt to incentivize self-disclosure to the federal government and self-imposed remedial measures by corporations charged with criminal wrongdoing....more

Cranfill Sumner LLP

DOJ Announces Sweeping Voluntary Corporate Self-Disclosure Policy

Cranfill Sumner LLP on

In late February, the United States Attorneys for the Southern and Eastern Districts of New York announced a new “Voluntary Self-Disclosure Policy” (VSD Policy), effective immediately, that applies to all United States...more

BakerHostetler

DOJ Announces Major Corporate Enforcement Policies

BakerHostetler on

Monaco’s and Polite’s remarks, and the DOJ’s new policies and guidance, come amid the Department’s increasingly tough on corporate crime approach and emphasis on rewarding companies that have effective compliance programs...more

Beveridge & Diamond PC

DOJ Implements Nationwide “Voluntary Self-Disclosure” Program: All U.S. Attorneys’ Offices Instructed to Follow Updated Corporate...

The U.S. Department of Justice (DOJ) formally implemented a nationwide Voluntary Self-Disclosure policy (VSD policy) on February 22, 2023—effective immediately—that has been in the works for several years. The VSD policy...more

Jenner & Block

Client Alert: DOJ Expands the Reach of Its Policies on Self-Disclosure of Corporate Misconduct

Jenner & Block on

On February 22, 2023, the Department of Justice announced a new Voluntary Self-Disclosure Policy (the Disclosure Policy) that now governs corporate prosecutions by US Attorney’s Offices (USAOs) nationwide. Building on a 2022...more

BakerHostetler

DOJ's Newly Revised Corporate Enforcement Policy Incentivizes Robust Compliance Programs, Cooperation and Remediation

BakerHostetler on

On Jan. 17, AAG Polite announced “the first significant changes” to the CEP since 2017. The policy revisions will apply to all corporate criminal matters handled by the Criminal Division and offer companies “new, significant,...more

Eversheds Sutherland (US) LLP

DOJ sweetens the deal for companies that “come forward, cooperate, and remediate”

On January 17, 2023, Assistant Attorney General Kenneth A. Polite, Jr. (AAG Polite) announced changes to the Department of Justice’s (DOJ) FCPA Corporate Enforcement Policy (CEP). The CEP, which applies to all Criminal...more

Holland & Knight LLP

DOJ Makes Significant Revisions to Corporate Enforcement Policy

Holland & Knight LLP on

The U.S. Department of Justice (DOJ), through Assistant Attorney General Kenneth A. Polite Jr., announced on Jan. 17, 2023, "the first significant changes" to its Corporate Enforcement Policy (CEP) since 2017. The revisions...more

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