News & Analysis as of

Department of Justice (DOJ) Disgorgement Enforcement Actions

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

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

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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

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

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

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

The Volkov Law Group

Catching Up with FCPA News

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DOJ closed out its FCPA enforcement year in 2022 with two significant settlements, the ABB and Honeywell cases.  Aside from these two big settlements, there was a flurry of other actions in the last quarter of 2022....more

White and Williams LLP

A Changing Climate: the Rising Tide of ESG Liability and Implications for D&O Coverage

The latest legal buzzword, ESG, represents the environmental, social and governance factors that many corporations are now required to consider and disclose alongside traditional financial information such as operating...more

The Volkov Law Group

DOJ Issues Declination to Global Advertising Company Under FCPA Enforcement Policy

The Volkov Law Group on

The Justice Department continues its enforcement “silence” with no major corporate prosecutions announced this year.  It is an interesting question but it appears that the wheels have ground to a halt, with one major...more

Holland & Knight LLP

Highlights from the SEC Division of Enforcement FY 2021 Annual Report

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The U.S. Securities and Exchange Commission's (SEC) Division of Enforcement (Division) published its Annual Report for Fiscal Year 2021 on Nov. 18, 2021. The Annual Report – the first issued under new Enforcement Director...more

Jones Day

JONES DAY TALKS®: Consumer Protection Enforcement Changes Likely After SCOTUS AMG Decision

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In AMG Capital Management v. FTC, the U.S. Supreme Court ruled the Federal Trade Commission Act does not allow the FTC to seek, from violators of the Act, "equitable monetary relief" in the form of restitution or...more

ArentFox Schiff

Managing Third-Party Risk: Recent FCPA Action Reflects Government’s Continued Focus on Intermediaries

ArentFox Schiff on

Amec Foster Wheeler Energy Limited (the Company), a subsidiary of John Wood Group plc (Wood), a United Kingdom-based global engineering company, agreed to pay more than $41 million in penalties and disgorgement for alleged...more

Winstead PC

What to Expect from the SEC Under the Biden Administration

Winstead PC on

The dust has settled on the 2020 election, and the Biden administration has begun pressing forward with its policy objectives. Critical to achieving such objectives is the Democrats’ control of both the House of...more

The Volkov Law Group

Vitol Pays $163.7 Million to Settle FCPA Case (Part I of III)

The Volkov Law Group on

The Justice Department continues to produce FCPA resolutions in a record year for enforcement.  The latest, and perhaps the beginning of several end-of-year and end of the Trump Administration resolutions, is DOJ’s settlement...more

K&L Gates LLP

Voluntary Disclosure: Newsflash July 2020

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A government inquiry can result in serious consequences for a company or individual. Our new podcast series, Voluntary Disclosure—brought to you by the lawyers in our investigations, enforcement, and white collar practice—is...more

McDermott Will & Schulte

[Webinar] Anti-Corruption and Compliance Training - May 28th, 10:00 am - 11:30 am EDT

Please join McDermott and Grant Thornton on Thursday, May 28, for a webinar training on anti-corruption and compliance. This training will discuss the auditing standards on illegal acts by clients and the auditor’s...more

Robins Kaplan LLP

Financial Daily Dose 3.3.2020 | Top Story: Promised Central Bank Action Halts Market Slide (for now)

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Despite news of additional COVID-19-related deaths and infections in America, central bankers appear to have bought at least one day of peace for US markets, which posted strong gains on a late surge on Monday, breaking a...more

Jones Day

FCPA 2019 Year in Review

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In the third year of the Trump Administration, the biggest Foreign Corrupt Practices Act ("FCPA") headlines were record corporate fines and penalties, and a banner year of individual FCPA enforcement highlighted by three DOJ...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2020 Insights

Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more

Baker Donelson

Justice Department Recovers $3 Billion in 2019 from False Claims Act Cases – $2.6 Billion Related to Health Care Industry

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This week the Department of Justice reported it recovered $3 billion from False Claims Act cases in 2019. Of that recovery amount, $2.1 billion resulted from whistleblower, or qui tam, actions. In addition, 633 new qui tam...more

Jones Day

SEC Enforcement in Financial Reporting and Disclosure: 2019 Year-End Update

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We are pleased to present our annual year-end update on financial reporting and issuer disclosure enforcement activity for 2019. This White Paper focuses on the U.S. Securities and Exchange Commission's ("SEC") enforcement...more

Eversheds Sutherland (US) LLP

DOJ further aligns Export Control and Sanctions Enforcement Policy with FCPA enforcement practices

On December 13, 2019, the US Department of Justice (DOJ) announced a revised Export Control and Sanctions Enforcement Policy for Business Organizations (Revised EC/S Policy), clarifying its prior guidance on voluntary...more

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