Criminal Prosecution, Federal Sentencing Guidelines, Non-Prosecution Agreements

DOJ’s Revised Self-Disclosure Policy May Offer Companies More Certainty

Troutman Pepper Locke on 6/25/2025

Last month, the DOJ Criminal Division (Division) revised its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), introducing several potentially significant changes intended to further incentivize companies to...more

Stericycle DPA signals more aggressive use of independent compliance monitors

Hogan Lovells on 5/5/2022

On April 20, 2022, the U.S. Department of Justice (DOJ) announced it had entered a three-year deferred prosecution agreement (DPA) with Stericycle Inc. to resolve allegations that it violated the Foreign Corrupt Practices Act...more

Technology Company Resolves DOJ And SEC FCPA Allegations, With Hungary Subsidiary Entering Three-Year, Monitor-Free NPA

A&O Shearman on 7/30/2019

On July 22, 2019, the United States Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced that they had resolved allegations of Foreign Corrupt Practice Act (“FCPA”) violations against...more

Drum Solo Week 5: Ringo and The End – Microsoft FCPA Settlement – Part 4

Thomas Fox - Compliance Evangelist on 7/26/2019

Initially, it would not seem that much was new or different about the Microsoft FCPA enforcement action but through this exploration, I think some clear lessons have emerge. The first is around internal controls. Here there...more

Drum Solo Week 4: In-A-Gadda-Da-Vida – Microsoft FCPA Settlement – Part 3

Thomas Fox - Compliance Evangelist on 7/25/2019

Continuing our use of great drum solos to consider the Microsoft Foreign Corrupt Practices Act (FCPA) enforcement action, today we consider what Microsoft did to obtain their result. We have previously considered the...more

Microsoft Pays DOJ and SEC $25 Million to Resolve FCPA Violations (Part I of III)

The Volkov Law Group on 7/25/2019

Microsoft finally resolved its FCPA enforcement action with a whimper. Notwithstanding prior suggestions that Microsoft’s investigation uncovered global conduct, Microsoft’s liability focused primarily on Microsoft’s conduct...more