News & Analysis as of

Declination Self-Reporting

Womble Bond Dickinson

Can a Whistleblower Derail a Deferred Prosecution Agreement?

Womble Bond Dickinson on

A recent whistleblower suit could impact a company’s deferred prosecution agreement (“DPA”) potentially leading to further investigation by DOJ and additional penalties. A whistleblower suit was recently filed in the New...more

Vedder Price

DOJ Criminal Division Announces Major Change in Corporate Enforcement Policy

Vedder Price on

On March 1, 2018, the Criminal Division of the U.S. Department of Justice (“DOJ”) announced that it has expanded the scope of cases in which it will consider issuing a formal declination of criminal charges for a company that...more

McGuireWoods LLP

Last Four Months of DOJ’s FCPA Pilot Program Could Provide Important Signals

McGuireWoods LLP on

Last April, the Criminal Division of the U.S. Department of Justice launched a one-year pilot program in the Fraud Section’s Foreign Corrupt Practices Act (“FCPA”) Unit. The pilot program, self-described as “building” on the...more

WilmerHale

A transatlantic consideration of recent developments in corporate self-reporting

WilmerHale on

More carrot, less stick? On 5 April 2016, the Fraud Section of the US Department of Justice’s (DOJ) Criminal Division issued an Enforcement Plan and Guidance (the DOJ Guidance), setting out the steps that it is taking to...more

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