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Department of Justice (DOJ) Disgorgement

A&O Shearman

First DOJ Declination For FCPA Violations Since Renewed Enforcement Guidelines

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On August 7, 2025, the United States Department of Justice, Criminal Division, Fraud Section (“DOJ”) issued a declination letter to a U.S.-based insurance company (the “Company”) to resolve alleged violations of the Foreign...more

The Volkov Law Group

Episode 383 -- FCPA Update: Declination and Indictment

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Is the DOJ really changing its playbook on FCPA enforcement, or is it business as usual under a new administration? In this episode, Michael digs into two headline developments that say a lot about where things are headed -...more

ArentFox Schiff

Liberty Mutual Resolution Shows Route to Declination and Roadmap for Compliance Investments

ArentFox Schiff on

The US Department of Justice (DOJ) declined to prosecute Liberty Mutual after the insurer voluntarily self-disclosed misconduct....more

The Volkov Law Group

Liberty Mutual Pays $4.7 Million for FCPA Declination

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In the first FCPA declination under the Trump Administration, Liberty Mutual Insurance Company paid $4.7 million in disgorgement and received a declination letter from the Department of Justice. The declination reflects...more

Davis Wright Tremaine LLP

CFTC Releases Its Enforcement Results for FY 2024 Showing an All-Time High for Monetary Relief

On December 4, 2024, the CFTC's Division of Enforcement ("Division") released its enforcement results for Fiscal Year 2024. The results reflected an all-time high for monetary relief, mainly from its resolution of off-channel...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for August 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

The Volkov Law Group

DOJ Awards Declination to Proterial Cable America for Fraud — Proterial Pays $15.1 Million in Disgorgement

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DOJ is pushing hard for voluntary disclosures and urging companies to take advantage  of its Voluntary Disclosure Program.  The carrot is significant — a declination in exchange for cooperation, remediation and disgorgement....more

The Volkov Law Group

DOJ Issues New FCPA Declination: Boston Consulting Group Pays $14.4 Million

The Volkov Law Group on

The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination.  But even a declination comes with a requirement — the company has...more

ArentFox Schiff

Investigations Newsletter: Commonwealth Financial Network Must Pay $72 Million in SEC Enforcement Action

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Commonwealth Financial Network Must Pay $72 Million in SEC Enforcement Action - Late last week, a Massachusetts federal judge ordered Commonwealth Financial Network to pay over $72 million due to its “egregious” failure to...more

Adams & Reese

Beyond Borders: Navigating Global Business Compliance with the FCPA

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On March 7th, the Department of Justice (DOJ) announced a new whistleblower reward program intended to help prosecutors bring more foreign corruption cases. Under the new program, individuals who report corporate misconduct...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for January 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

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for November 2023

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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

White & Case LLP

A View from Abroad: Unpacking DOJ’s M&A Safe Harbor Policy, Part II

White & Case LLP on

On October 4, 2023, United States Deputy Attorney General (DAG) Lisa Monaco announced a new Department of Justice (DOJ) Mergers & Acquisitions Safe Harbor policy that encourages companies to self-disclose criminal misconduct...more

Ankura

U.S. DOJ’s New Safe Harbor Policy: Conducting Enhanced M&A Due Diligence

Ankura on

Last month, U.S. Deputy Attorney General Lisa O. Monaco announced a new Safe Harbor Policy for voluntary self-disclosure (the “Policy”) made in connection with merger and acquisition activity. The Policy is intended to bring...more

King & Spalding

Reconsider That Term Sheet: DOJ "Safe Harbor Policy" Announcement Incentivizes Merger-Related Disclosures

King & Spalding on

On October 4, 2023, the Department of Justice’s (“DOJ”) Deputy Attorney General Lisa Monaco announced a new “Mergers & Acquisitions Safe Harbor Policy” (“M&A Safe Harbor Policy” or “Policy”) for companies that voluntarily...more

Dorsey & Whitney LLP

Department of Justice Seeks to Reward Due Diligence and Timely Self-Disclosures in Mergers & Acquisitions Through New Safe Harbor...

Dorsey & Whitney LLP on

The United States Department of Justice (DOJ) recently announced a new department-wide Mergers & Acquisitions Safe Harbor Policy that protects acquiring companies that self-disclose criminal misconduct discovered at an...more

Vinson & Elkins LLP

To Self-Report or Not to Self-Report: With New M&A Safe Harbor Policy, DOJ Tries to Answer the Question

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It is one of the hardest questions a company can face: after discovering criminal conduct inside your company, do you self-report to the government or not? If you can quickly and quietly fix the problem, then you may be able...more

Foley & Lardner LLP

Implications of DOJ’s New Safe Harbor for Disclosing Misconduct Uncovered During M&A Transactions

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U.S. Deputy Attorney General Lisa Monaco recently announced that the Department of Justice (DOJ) is adopting a new safe harbor policy to incentivize corporations to voluntarily self-disclose criminal misconduct discovered...more

BakerHostetler

DOJ Announces Department-Wide Safe Harbor Policy for Voluntary Self-Disclosures Made in the Context of Mergers and Acquisitions

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In an important policy announcement aimed at rewarding robust due diligence and compliance programs, DOJ announced that acquiring companies that promptly and voluntarily disclose criminal misconduct discovered at the acquired...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 1 – Background

Last week, Albemarle Corporation (Albemarle), a publicly traded specialty chemicals manufacturing company headquartered in North Carolina, agreed to pay more than $218 million to resolve investigations by the U.S. Department...more

The Volkov Law Group

Albemarle Settles DOJ and SEC FCPA Cases for $218 Million (Part I of III)

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Albemarle Corporation (Albemarle), a specialty chemicals manufacturing company located in Charlotte, North Carolina, agreed to pay more than $218 million to settle FCPA investigations with DOJ and the SEC stemming from...more

Womble Bond Dickinson

Handle with Care: FCPA Travel & Hospitality Expenses

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Two recent Foreign Corrupt Practices Act (FCPA) actions – a Department of Justice (DOJ) Opinion letter and an SEC settlement – underscore key diligence questions that legal and compliance departments should address when...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for April 2023

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

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for March 2023

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

The Volkov Law Group

Corsa Coal Earns Declination and Agreed to Disgorge $1.2 Million

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The Justice Department has been pushing its voluntary self-disclosure program and changes to its Corporate Enforcement Policy, in an attempt to increase FCPA enforcement cooperation.  The Golden Ring for every company facing...more

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