News & Analysis as of

Department of Justice (DOJ) Corporate Misconduct Corporate Monitoring

Benesch

The Exception, Not the Rule: DOJ’s Updated Corporate Compliance Monitorship Guidance

Benesch on

On May 12, 2025, the United States Department of Justice’s Criminal Division published a series of memoranda outlining updated white-collar enforcement priorities. ...more

Brownstein Hyatt Farber Schreck

DOJ Issues New Guidance on White-Collar Prosecutions and Corporate Monitors

On May 12, 2025, the current head of the Department of Justice’s (DOJ) Criminal Division issued fresh guidance to all personnel under his purview with new two memoranda....more

Morgan Lewis

DOJ Revises Corporate Monitor Policy with New Cost and Oversight Rules

Morgan Lewis on

On May 12, 2025, the US Department of Justice’s Criminal Division published a set of memoranda outlining white collar enforcement priorities and an updated outlook on the imposition and selection of corporate monitors. The...more

Morrison & Foerster LLP

CFTC Director of Enforcement Ian McGinley Announces Updates to Corporate and Individual Enforcement Polices

Morrison & Foerster LLP on

On October 17, 2023, during a speech at the Program on Corporate Compliance and Enforcement held at the New York University School of Law, the Commodity Futures Trading Commission (CFTC) Director of Enforcement, Ian McGinley,...more

StoneTurn

Meeting DOJ and SEC Post-Settlement Obligations: A Practical Guide

StoneTurn on

No Longer Just a Matter of Paying the Fine and Moving On. Corporate settlement agreements used to be straightforward—pay the penalty and move on. Now, these resolutions rival complex business transactions, including...more

Porter Hedges LLP

U.S. Attorneys’ Offices Implement New Voluntary Self-Disclosure Policy

Porter Hedges LLP on

On February 22, 2023, the U.S. Department of Justice’s (DOJ) United States Attorneys’ Offices (USAO) announced a new Voluntary Self-Disclosure Policy that went into immediate effect. The purpose of the new policy is to create...more

A&O Shearman

The DOJ Reinforces And Updates Corporate Criminal Enforcement Priorities With Speech By Deputy Attorney General Lisa O. Monaco

A&O Shearman on

On September 15, 2022, Deputy Attorney General Lisa O. Monaco delivered remarks on the Department of Justice’s corporate prosecution priorities at New York University, at the invitation of the University’s Project on...more

BakerHostetler

Deputy AG Lisa Monaco Announces Tough-on-Corporate-Crime Updates to DOJ Policies

BakerHostetler on

In prepared remarks delivered at New York University School of Law on Sept. 15, Deputy AG Monaco announced significant updates to the DOJ’s corporate criminal enforcement policies. Deputy AG Monaco’s announcement...more

WilmerHale

The Corporate Crime Advisory Group Has Spoken: DOJ Revises Corporate Criminal Enforcement Policies

WilmerHale on

On September 15, 2022, the Department of Justice (Department) released a memorandum revising several key aspects of its corporate criminal enforcement policies. The new policy, titled Further Revisions to Corporate Criminal...more

Vinson & Elkins LLP

Why Voluntary Independent Compliance Monitorships Are Growing in Popularity

Vinson & Elkins LLP on

When companies get into trouble, it’s common practice for the government to call on independent third parties to help clean up the mess. Companies under investigation by the Department of Justice (“DOJ”) often agree to...more

Katten Muchin Rosenman LLP

DOJ Signals Increased Use of Corporate Monitors

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 Volkov Law Group

Deputy AG Lisa Monaco Suggests Major Changes to the DOJ’s Corporate Enforcement Efforts

The Volkov Law Group on

On October 28, 2021, U.S. Deputy Attorney General Lisa O. Monaco—a veteran of government service in previous Administrations and a champion of corporate accountability—announced several significant changes to current...more

Latham & Watkins LLP

Senior US DOJ Official Sets Forth New Priorities for Pursuing Corporate Crime

Latham & Watkins LLP on

The priorities will impact non-US companies who may face a US DOJ with a renewed emphasis on combating corporate crime. In a recent speech that has garnered significant attention, the Deputy Attorney General of the...more

Thomas Fox - Compliance Evangelist

It’s The Great Pumpkin Charlie Brown - Lessons in Process Validation Through Continuous Monitoring

Halloween is almost upon us and we celebrate the greatest Halloween cartoon in the history of the world, ever, “It’s the Great Pumpkin, Charlie Brown”, which premiered in 1966. As usual, the story revolves around the Peanuts...more

Skadden, Arps, Slate, Meagher & Flom LLP

Ericsson Agrees To Pay Over USD $1 Billion To Settle FCPA Charges

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

The Volkov Law Group

Episode 119 -- The Ericsson FCPA Settlement

The Volkov Law Group on

The Sweden-based telecommunications company, Ericsson, agreed to a pay a total of $1 billion (yes, billion with a “B”) for FCPA violations. Ericsson entered into settlement agreements with DOJ and the SEC. Ericsson agreed to...more

Thomas Fox - Compliance Evangelist

Walmart FCPA Enforcement Action: Part 1 – Introduction

The big one finally is resolved. The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced yesterday. This massive case came in with multiple documents, a long list of...more

The Volkov Law Group

Justice Department Recalibrates Corporate Monitors and DOJ Compliance Position

The Volkov Law Group on

In a recent speech, Brian Benczkowski, the Assistant Attorney General for the Criminal Division outlined the Justice Department’s new policy governing imposition of a corporate compliance monitor. ...more

A&O Shearman

DOJ Announces Updated Policy On Selection Of Corporate Monitors

A&O Shearman on

On October 11, 2018, the U.S. Department of Justice (“DOJ”) released an updated policy regarding the selection of corporate monitors. The policy—entitled “Selection of Monitors in Criminal Division Matters” (“Policy”)—is...more

Holland & Knight LLP

DOJ Issues New Guidance on Necessity and Selection of Corporate Monitors

Holland & Knight LLP on

• Assistant Attorney General Brian A. Benczkowski's recent Memorandum on "Selection of Monitors in Criminal Division Matters" provides new direction to U.S. Department of Justice (DOJ) prosecutors regarding when to require...more

Skadden, Arps, Slate, Meagher & Flom LLP

Second Circuit Upholds Prosecutorial Discretion in Deferred Prosecution Agreements

On July 12, 2017, the U.S. Court of Appeals for the Second Circuit ruled in United States v. HSBC Bank USA, N.A. that a federal district court does not have the authority to supervise the implementation of a deferred...more

Thomas Fox - Compliance Evangelist

Day 18 of One Month to More Effective Continuous Improvement-Email Sweeps for Continuous Improvement

Ongoing monitoring is not limited to the financial component of compliance. Another approach to review emails as both a preventative and detection program through the technique of email sweeps. The concept is straightforward;...more

Thomas Fox - Compliance Evangelist

Day 16 of One Month to More Effective Continuous Improvement-Voluntary Monitoring

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

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