News & Analysis as of

Department of Justice (DOJ) Voluntary Disclosure

Williams Mullen

U.S. Justice Department Renews Enforcement Focus on Health Care Fraud

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In recent weeks, the Justice Department has issued new charging guidelines and announced enforcement actions that reflect the priorities of the current administration. Targeting perceived health care fraud, particularly...more

Bass, Berry & Sims PLC

Sanctions Enforcement Update: DOJ Declines Prosecution After Post-Acquisition Disclosure

In June 2025, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) announced that Unicat Catalyst Technologies, LLC (Unicat), a Texas-based petrochemical company, had agreed to settle its potential civil liability...more

Hogan Lovells

Back in Business? What the DOJ’s FCPA reset means for the SFO and UK companies

Hogan Lovells on

On 9 June 2025, the U.S. Department of Justice (DOJ) published revised guidance for the enforcement of the Foreign Corrupt Practices Act (FCPA). Much attention has been paid to the apparent “unpausing” of enforcement...more

A&O Shearman

U.S. DOJ first declination for sanctions violation since creation of M&A safe harbor

A&O Shearman on

On June 16, 2024, the U.S. Department of Justice’s (DOJ) National Security Division (NSD) and the U.S. Attorney’s Office for the Southern District of Texas (SDTX) announced the first-ever declination to prosecute a firm and...more

A&O Shearman

DOJ Issues First-Ever Declination For Sanctions Violations Since Creation Of The M&A Safe Harbor Policy

A&O Shearman on

On June 16, 2024, the U.S. Department of Justice’s (“DOJ”) National Security Division (“NSD”) and the U.S. Attorney’s Office for the Southern District of Texas (“SDTX”) announced the first-ever declination to prosecute a firm...more

McDermott Will & Emery

From risk to relief: PE firm avoids prosecution with swift disclosure

In June 2025, the US Department of Justice (DOJ) announced that it declined to prosecute a private equity firm and its affiliates following the firm’s voluntary self-disclosure of criminal violations of US sanctions and...more

Paul Hastings LLP

DOJ’s M&A Safe Harbor Highlights Importance of Post-Close Due Diligence and Integration

Paul Hastings LLP on

On June 16, the U.S. Department of Justice’s (DOJ’s or Department’s) National Security Division (NSD or Division) announced they had declined to prosecute the private equity firm White Deer Management LLC for violations of...more

The Volkov Law Group

Lessons Learned from the Unicat Settlement (Part III of III)

The Volkov Law Group on

The Unicat settlement provides some important insights into the Trump Administration’s direction on trade enforcement. It underscores the importance of voluntary disclosure, cooperation and remediation, the tri-part...more

Proskauer Rose LLP

DOJ Declination of Private Equity Firm Underscores Need for Robust M&A Due Diligence

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On June 16, 2025, the U.S. Department of Justice (“DOJ”), including its National Security Division (“NSD”) and the U.S. Attorney’s Office for the Southern District of Texas, announced that they would not prosecute White Deer...more

The Volkov Law Group

DOJ’s Coordinated Resolution with Unicat Resolves OFAC, BIS and CBP Violations (Part II of III)

The Volkov Law Group on

DOJ’s Unicat resolution is a perfect example of the new trade enforcement reality under the Trump Administration.  DOJ spearheaded a global resolution of sanctions, customs and export controls violations, while declining to...more

The Volkov Law Group

Unicat Settles with DOJ and Resolves Sanctions, Export Controls and Customs Violations Applying Voluntary Disclosure Policy in M&A...

The Volkov Law Group on

In an interesting enforcement action reflecting the Administration’s priority on sanctions, export and customs enforcement, DOJ announced a global resolution with DOJ, OFAC, BIS and CBP and Unicat Catalyst Technologies...more

Hogan Lovells

The NSD declines prosecution for the first time under its M&A Policy

Hogan Lovells on

On June 16, 2025, the U.S. Department of Justice (DOJ) publicly announced that it had declined to prosecute White Deer Management LLC (White Deer) and certain affiliates for violations of sanctions law and related conduct....more

Troutman Pepper Locke

DOJ’s Revised Self-Disclosure Policy May Offer Companies More Certainty

Troutman Pepper Locke on

Last month, the DOJ Criminal Division (Division) revised its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), introducing several potentially significant changes intended to further incentivize companies to...more

Wiley Rein LLP

DOJ’s Approach to White Collar Enforcement: Target Those Who Harm U.S. Interests While Minimizing Collateral Damage

Wiley Rein LLP on

The U.S. Department of Justice (DOJ) recently announced Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA). The June 9 memorandum from Deputy Attorney General Todd Blanche instructs...more

Morrison & Foerster LLP

DOJ Issues First-Ever Declination Under Corporate Disclosure M&A Policy

On June 16, 2025, the Department of Justice (DOJ) National Security Division (NSD) announced that it declined to charge private equity firm White Deer Management LLC (“White Deer”) and its affiliates after the company...more

DLA Piper

Private Equity Acquirer Avoids “Unicat-astrophe” Following Voluntary Disclosures to the DOJ

DLA Piper on

The US Department of Justice (DOJ) announced that it has formally declined to prosecute private equity firm White Deer Management LLC (White Deer) and certain of its affiliates in connection with criminal violations of US...more

White & Case LLP

DOJ Declines to Prosecute Private Equity Firm after Post-Acquisition Voluntary Self-Disclosure of Sanctions and Export Control...

White & Case LLP on

In its first application of the policy on voluntary self-disclosures (“VSDs”) in connection with mergers and acquisitions (“M&A”), on June 16, 2025, the US Department of Justice’s (“DOJ”) National Security Division (“NSD”)...more

Baker Donelson

Update: DOJ Issues Guidelines for Protectionist FCPA Enforcement

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In February, the White House issued an Executive Order "pausing" Foreign Corrupt Practices Act (FCPA) enforcement for 180 days, to "further American economic and national security."1 On June 9, Deputy Attorney General Todd...more

Alston & Bird

A DOJ Private Equity Declination and Its Lessons for Acquirers and Targets

Alston & Bird on

The DOJ declined to prosecute a private equity firm for its portfolio company’s pre-acquisition sanctions and export violations, marking the first application of the National Security Division’s M&A Policy. Our White Collar,...more

Eversheds Sutherland (US) LLP

DOJ declines prosecution for PE firm after post-acquisition voluntary self-disclosure

On June 16, 2025, the Department of Justice (DOJ) National Security Division (NSD) and the US Attorney’s Office for the Southern District of Texas announced the first declination of prosecution for an acquirer that...more

Rivkin Radler LLP

The Latest Refinements to DOJ’s White Collar Enforcement Policy

Rivkin Radler LLP on

Last month, the head of the Criminal Division of the U.S. Department of Justice (DOJ), Matthew R. Galeotti, issued a Memorandum outlining DOJ’s enforcement priorities and policies for prosecuting white-collar crime,...more

Society of Corporate Compliance and Ethics...

Understanding the DOJ's Recent Corporate Enforcement Policy Changes

On May 12, 2025 the head of the Criminal Division at the US Department of Justice issued a memo to all Criminal Division personnel with the subject: Focus, Fairness and Efficiency in the Fight Against White Collar Crime. To...more

McGlinchey Stafford

DOJ Overhauls Corporate Enforcement, Disclosure Policy, Offering Clearer Path to Leniency

McGlinchey Stafford on

The decision for a company to self-disclose potential criminal misconduct to the U.S. Department of Justice (DOJ) is always complex. This is particularly true during periods of administration transitions when DOJ policies and...more

Proskauer - The Capital Commitment

Why the DOJ’s New Whistleblower Program Remains Relevant

On May 12, 2025, the U.S. Department of Justice (DOJ) issued a memorandum outlining the Criminal Division’s enforcement priorities and policies for prosecuting corporate and white-collar crimes in the new Administration....more

Proskauer Rose LLP

DOJ Adopts Risk-Based Approach in FCPA & White-Collar Enforcement Policy Shift

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On June 9, 2025, the U.S. Department of Justice (“DOJ”) issued guidelines governing investigations and the enforcement of the Foreign Corrupt Practices Act (FCPA), following through on commitments made in President Trump’s...more

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