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Department of Justice (DOJ) Remediation Cooperation

Carlton Fields

DOJ Policy Changes Have Made Internal Investigations More Important Than Ever

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Internal investigations have long been a valuable tool for companies and their executives to manage civil, regulatory, and criminal liability. By investigating potential corporate misconduct with the help of counsel, a...more

BakerHostetler

The CFTC Announces a New System To Incentivize Self-Reporting, Cooperation, and Remediation

BakerHostetler on

On February 25, 2025, the CFTC released an Enforcement Advisory on Self-Reporting, Cooperation, and Remediation, introducing metrics the Division will use to evaluate a company’s or individual’s conduct before and leading up...more

Thomas Fox - Compliance Evangelist

Argentieri Speech: 6 Key Takeaways for the Compliance Programs

On Monday, Principal Deputy Assistant Attorney General Nicole M. Argentieri spoke at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute. ( A copy of her remarks can be found here.) She...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

DOJ’s Emphasis Of Individual Accountability – Where It Stands, And Where It Could Be Headed

A recent article in Law360 sparked a vigorous conversation among members of Pietragallo’s white collar practice group about the current state of the U.S. Department of Justice’s (DOJ) evolving emphasis on individual...more

White & Case LLP

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

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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

Holland & Knight LLP

Cooperation with SEC: Yielding More Benefits, but Lack of Predictability Remains

Holland & Knight LLP on

Although the SEC has long adhered to its Seaboard Report of Investigation to outline the analytical framework for the agency's cooperation program for companies, the exact benefits of self-policing, self-reporting,...more

Holland & Knight LLP

Understanding the Department of Justice's New Safe Harbor Policy

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Continuing its focus on incentivizing prompt and voluntary self-disclosure of criminal misconduct, Deputy Attorney General Lisa Monaco announced earlier this month a new U.S. Department of Justice (DOJ) Safe Harbor Policy...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

BakerHostetler

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

BakerHostetler on

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

Venable LLP

Honesty is Good for Your Bottom Line: Commerce, Treasury, and DOJ Tout the Benefits of Voluntary Self Disclosure in Tri-Seal...

Venable LLP on

Voluntary self-disclosure is a valuable remediation measure for companies who identify their own potential violations of U.S. sanctions, export controls, and other national security laws....more

Society of Corporate Compliance and Ethics...

[Virtual Event] Corporate Compliance Enforcement Conference - July 25th, 9:00 am - 4:45 pm CT

Is Your Compliance Program Designed for the Current Enforcement Landscape? Data protection, anti-corruption, antitrust, supply chains, economic sanctions and even the software employees use to communicate are all subjects...more

Latham & Watkins LLP

DOJ’s Updated Corporate Enforcement Policy Aims to Incentivize Compliance

Latham & Watkins LLP on

Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors. In a speech at Georgetown University Law Center on...more

Mintz - Health Care Viewpoints

Garland Memo May Provide White Collar Defendants Increased Opportunity for Negotiation While Updated Corporate Enforcement Policy...

In recent weeks, the Department of Justice has released key guidance in the form of a memorandum from Attorney General Garland regarding charging, pleas, and sentencing, in addition to an updated Corporate Enforcement Policy...more

BakerHostetler

DOJ's Newly Revised Corporate Enforcement Policy Incentivizes Robust Compliance Programs, Cooperation and Remediation

BakerHostetler on

On Jan. 17, AAG Polite announced “the first significant changes” to the CEP since 2017. The policy revisions will apply to all corporate criminal matters handled by the Criminal Division and offer companies “new, significant,...more

Dorsey & Whitney LLP

DOJ Announces Additional Incentives for Corporate Cooperation in Criminal Enforcement

Dorsey & Whitney LLP on

On January 17, 2023, Assistant Attorney General for the United States Department of Justice Kenneth A. Polite Jr. announced significant revisions to the Criminal Division’s Corporate Enforcement Policy (“CEP”). Four months...more

Holland & Knight LLP

DOJ Makes Significant Revisions to Corporate Enforcement Policy

Holland & Knight LLP on

The U.S. Department of Justice (DOJ), through Assistant Attorney General Kenneth A. Polite Jr., announced on Jan. 17, 2023, "the first significant changes" to its Corporate Enforcement Policy (CEP) since 2017. The revisions...more

Jones Day

Corporate Internal Investigations: Keys to an Effective Work Plan, Data and Document Management, and Budget

Jones Day on

As described in the first White Paper in this series on internal investigations, "Conducting an Effective Internal Investigation—An Overview," corporations are under increased scrutiny by regulators across the globe, and as a...more

Society of Corporate Compliance and Ethics...

What do you mean, "cooperate"?

CEP Magazine (September 2022) - This month’s column is about something I hope you never have to address: cooperating with government officials in connection with an investigation into a compliance violation at your...more

Society of Corporate Compliance and Ethics...

Compliance Perspectives: The Antitrust Division’s Office of Decree Enforcement

The approach to compliance programs of the Antitrust Division at the US Department of Justice has evolved considerably over the last few years, starting with the release of their watershed Evaluation of Corporate Compliance...more

Snell & Wilmer

No Prosecution, No Fine Presumption for Companies that Voluntarily Self Disclose Potentially Willful Violations of Export and...

Snell & Wilmer on

On December 13, 2019, the Department of Justice (DOJ) updated its enforcement guidelines to include a no-fine, no-prosecution presumption for companies that voluntarily self-disclose potentially willful violations of the...more

WilmerHale

Airbus to Pay Record $4 Billion to Settle Global Bribery Scheme

WilmerHale on

On January 31, 2020, the Department of Justice (“DOJ”) agreed to resolve allegations that Airbus SE (“Airbus”), a France-based aerospace company, used third-party business partners to bribe government officials and airline...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

WilmerHale

$1 Billion Ericsson Resolution, Three Jury Verdicts Cap Off Busy Fourth Quarter for US FCPA Enforcement

WilmerHale on

On December 6, 2019, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) agreed to resolve allegations that multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson or...more

BCLP

DOJ Issues Policy for Export Control and Sanctions Enforcement (IRB No. 580)

BCLP on

On December 13, 2019, the US Department of Justice (DOJ) issued an update to its 2016 guidance regarding enforcement in export control and sanctions investigations of businesses.  The updated policy now offers voluntary...more

Eversheds Sutherland (US) LLP

DOJ revises FCPA corporate enforcement policy to clarify self-disclosure and cooperation credit requirements

On November 20, 2019, the US Department of Justice (DOJ) announced the latest revisions to the Foreign Corrupt Practices Act Corporate Enforcement Policy (the Corporate Enforcement Policy). The revised language provides...more

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