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Bass, Berry & Sims PLC

(Insider) Trading under a Rule 10b5-1 Plan

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In June 2025, Terren Scott Peizer, the former chief executive officer, executive chairman and chairman of the board of directors of Ontrak, Inc. (Ontrak), was sentenced to 42 months imprisonment, ordered to pay a $5.25...more

Morrison & Foerster LLP

DOJ Issues First-Ever Declination Under Corporate Disclosure M&A Policy

On June 16, 2025, the Department of Justice (DOJ) National Security Division (NSD) announced that it declined to charge private equity firm White Deer Management LLC (“White Deer”) and its affiliates after the company...more

Rivkin Radler LLP

The Latest Refinements to DOJ’s White Collar Enforcement Policy

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Last month, the head of the Criminal Division of the U.S. Department of Justice (DOJ), Matthew R. Galeotti, issued a Memorandum outlining DOJ’s enforcement priorities and policies for prosecuting white-collar crime,...more

Whiteford

Client Alert: Department of Justice’s New White Collar Crime Focus

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The Department of Justice’s Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime memorandum released on May 12, 2025, signals a shift in DOJ corporate criminal enforcement. The memorandum signals a shift...more

Jones Day

DOJ Criminal Division Announces Priority Enforcement Areas and Publishes Revised Enforcement Guidance

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On May 12, 2025, the Department of Justice Criminal Division announced significant changes to its corporate white-collar criminal enforcement priorities. In line with the Trump administration’s recalibration toward...more

Katten Muchin Rosenman LLP

Think Compliance Got Easier? Think Again—DOJ’s New Era in White-Collar Enforcement (Part 3)

In our prior two posts, we’ve delved into the memorandum issued by the Head of the Department of Justice’s (Department) Criminal Division, Matthew R. Galeotti—"Focus, Fairness, and Efficiency in the Fight Against White-Collar...more

Pillsbury Winthrop Shaw Pittman LLP

DOJ Announces Shift in Approach to Prosecuting Corporate Crime

The Criminal Division’s revisions to white-collar enforcement policies seek a new balance between uncovering corporate crime and unencumbering American businesses....more

Paul Hastings LLP

Criminal Division White Collar Enforcement Plan: Turning the Page, Not Writing a New Book

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On May 12, the Head of the U.S. Department of Justice (DOJ) Criminal Division, Matthew Galeotti, delivered remarks at the Securities Industry and Financial Markets Association’s Anti-Money Laundering and Financial Crimes...more

Hogan Lovells

DOJ corporate enforcement overhaul: More declinations, fewer monitors, and FCPA enforcement still in question

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On May 12, 2025, the U.S. Department of Justice (DOJ) announced revisions to key corporate criminal enforcement policies. The revisions’ stated aim is to provide more clarity and certainty of outcome to companies that...more

The Volkov Law Group

DOJ Announces New White Collar Enforcement Strategy (Part I of III)

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With each new Administration comes a new approach or emphasis on certain enforcement priorities. The Trump Administration is marking its territory and doing so to underscore its priorities. In a recent speech, the...more

Sheppard Mullin Richter & Hampton LLP

DOJ’s Updated Enforcement Policy: A Game-Changer for Corporate America?

On May 12, 2025, the U.S. Department of Justice (DOJ) announced a major overhaul of its corporate enforcement policy, aiming to incentivize companies to voluntarily self-disclose misconduct. Titled “Focus, Fairness, and...more

Snell & Wilmer

DOJ Announces Updated Corporate and White-Collar Enforcement Policy

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On May 12, 2025, Matthew R. Galeotti — Head of the U.S. Department of Justice (DOJ) Criminal Division — issued an updated enforcement policy detailing the Criminal Division’s priorities for prosecuting corporate and...more

Epstein Becker & Green

Department of Justice Outlines New White-Collar Crime Enforcement Priorities: Part One

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On May 12, 2025, the U.S. Department of Justice’s Criminal Division released a new guidance memo on white-collar enforcement priorities in the Trump Administration entitled “Focus, Fairness, and Efficiency in the Fight...more

Baker Botts L.L.P.

Ninth Circuit Upholds Conviction of Former Uber Security Chief Joseph Sullivan in Connection with 2016 Uber Data Security Breach

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On March 13, 2025, a three-judge panel of the U.S. Court of Appeals for the Ninth Circuit unanimously upheld the conviction of former Uber Chief Security Officer Joseph Sullivan. The ruling affirms Sullivan’s 2022 conviction...more

Holland & Knight LLP

Former MoviePass Executive Consents and Pleads Guilty in Parallel SEC and DOJ Cases

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In Hollywood, the sequel (or, even more so, the third installment) is rarely as good as the original movie. In the world of enforcement, the same rings true....more

Fox Rothschild LLP

“You Have the Right to Remain Silent” . . . Criminalization of Aviation Accidents

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In the second in our Aviation Symposium series of blog posts, we present the materials from the great panel we had discussing the criminalization of aviation accidents. We were fortunate enough to have renowned criminal...more

Herbert Smith Freehills Kramer

Second Circuit Affirms Order Compelling Disclosure of Attorney-Client Communications Subject to the Crime-Fraud Privilege...

On Feb. 7, 2025, the U.S. Court of Appeals for the Second Circuit in In re Two Grand Jury Subpoenas Dated Sept. 13, 2023 affirmed the Southern District of New York’s order compelling a partner at a law firm and the firm to...more

Ballard Spahr LLP

Attorney General Bondi Overhauls Justice Priorities

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The new administration has signaled that the Department of Justice (“DOJ”) will significantly shift its approach to criminal corporate enforcement. Specifically, on February 5, 2025, newly-confirmed United States Attorney...more

Latham & Watkins LLP

Top Tips for Global Companies Preparing for the UK’s New “Failure to Prevent Fraud” Offence

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Companies in the US and around the world should consider their potential for UK exposure and assess their compliance programmes in light of that risk. On 1 September 2025, the UK will implement a new corporate criminal...more

Lowenstein Sandler LLP

Long Live the FCPA?

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The Trump administration has taken significant action this week to overhaul the executive branch’s long-standing policy toward the prosecution of white collar offenses. First, a memo issued by newly confirmed U.S. Attorney...more

BCLP

Crime-Fraud Exception Destroys Privilege for Communications Between Former CEO of Public Company and His Outside Lawyer

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On February 7, 2025, the Second Circuit ruled that the crime-fraud exception would prevent the  former CEO of a public company from invoking attorney-client privilege to prevent an outside lawyer and his law firm from...more

Health Care Compliance Association (HCCA)

Private-pay “crime stoppers”: Digesting the Corporate Whistleblower Awards Pilot Program

The U.S. Department of Justice’s (DOJ) Criminal Division launched its Corporate Whistleblower Awards Pilot Program (“Criminal Whistleblower Program”) in August of 2024 to encourage tips for various types of fraud, including...more

The Volkov Law Group

FCPA Predictions: Don’t Expect Much to Change

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In 2017, when President Trump first took office, big changes were expected in FCPA enforcement.  Much of this reflected President Trump’s expressed misgivings on the substance of the FCPA.  He was not a big fan of the law and...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments: 2024 Year in Review

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this special edition of our award-winning monthly Top 10 International Anti-Corruption Developments newsletter summarizes the most...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for December 2024

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

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