News & Analysis as of

Department of Justice (DOJ) Voluntary Disclosure Corporate Misconduct

A&O Shearman

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

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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

Paul Hastings LLP

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

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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

Troutman Pepper Locke

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

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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

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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

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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

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

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

Carlton Fields

DOJ Policy Changes Have Made Internal Investigations More Important Than Ever

Carlton Fields on

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

Ropes & Gray LLP

DOJ’s New FCPA Playbook: “Time To Get To Work”

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On June 9, 2025, the U.S. Department of Justice (“DOJ” or the “Department”) issued the highly anticipated guidelines for investigations and enforcement of the Foreign Corrupt Practices Act (“FCPA”) (“FCPA Guidelines”),...more

Whiteford

Client Alert: Department of Justice’s New White Collar Crime Focus

Whiteford on

The Department of Justice’s Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime memorandum released on May 12, 2025, signals a shift in DOJ corporate criminal enforcement. The memorandum signals a shift...more

Vinson & Elkins LLP

Focus, Fairness, & Efficiency: DOJ White Collar Policy Shifts Signal Recalibration, But Not Revolution in Enforcement

Vinson & Elkins LLP on

On May 12, 2025, the Criminal Division of the U.S. Department of Justice (“DOJ” or the “Department”) issued a series of significant policy changes outlining the Trump administration’s new approach to white-collar enforcement....more

Wilson Sonsini Goodrich & Rosati

DOJ Streamlines Voluntary Self-Disclosure Policy for More Favorable Corporate Criminal Resolutions

When a company detects potential criminal misconduct, it must decide whether to self-disclose the misconduct to the U.S. Department of Justice (DOJ). This decision—while always complicated—is even more difficult during...more

Cohen Seglias Pallas Greenhall & Furman PC

DOJ Increases Incentives to Self-Disclose with Revised Corporate Enforcement Policy

Earlier this month, the Department of Justice (DOJ) announced revisions to the Corporate Enforcement and Self Disclosure Policy (CEP). Under the new policy, announced by DOJ Criminal Division Head Matthew Galeotti, companies...more

Saul Ewing LLP

DOJ's New Direction: Implications of the Trump Administration's Recently Announced Corporate Enforcement Framework

Saul Ewing LLP on

A Significant Shift in White Collar Criminal Enforcement - The Department of Justice (“DOJ”) has unveiled a comprehensive plan for its white-collar crime enforcement strategy, laying out the “high-impact” areas where...more

BakerHostetler

DOJ Criminal Division Announces Leniency and Potential Declination for Companies That Self-Disclose

BakerHostetler on

Earlier this month, the DOJ’s Criminal Division Head, Matthew R. Galeotti, spoke at the Securities Industry and Financial Markets Association’s (SIFMA) Anti-Money Laundering and Financial Crimes Conference in Washington,...more

Ice Miller

The DOJ’s Evolving Policies: White-Collar Enforcement Under President Trump

Ice Miller on

On May 12, 2025, the head of the Department of Justice’s (DOJ) Criminal Division, Matthew R. Galeotti, outlined the Trump Administration’s enforcement framework for white collar crime. ...more

Mintz - Health Care Viewpoints

Voluntary Self-Disclosure and Whistleblower Awards Initiatives Are Alive and Well in 2025: DOJ Issues White-Collar Enforcement...

The first 120 days of the Trump administration have been characterized by dramatic changes in the realm of white-collar enforcement. However, in the midst of a period wrought with uncertainty over what the administration may...more

Patterson Belknap Webb & Tyler LLP

DOJ Announces Guidance on White Collar Enforcement Priorities and Corporate Cooperation

On May 12, 2025, Matthew Galeotti, the Head of the Criminal Division of the Department of Justice (“DOJ”), announced changes to DOJ’s white collar enforcement priorities and corporate cooperation policy. During a speech on...more

Epstein Becker & Green

With New White Collar Enforcement Priorities Memo, DOJ Seeks to Provide More Pathways to Declinations and Non-Prosecution...

Epstein Becker & Green on

In Part One of this series, we discussed the May 12, 2025, U.S. Department of Justice Criminal Division’s new guidance memo on white-collar enforcement priorities in the Trump 2.0 Administration entitled “Focus, Fairness, and...more

Epiq

The New DOJ Position on Self-Disclosure Demands High-Functioning Compliance

Epiq on

In remarks to an industry group, Matthew R. Galeotti, head of the Department of Justice (DOJ) Criminal Division, emphasized that companies may avoid criminal resolutions if they voluntarily self-disclose misconduct, fully...more

The Volkov Law Group

DOJ Expands Whistleblower Program to Include Tariffs, Sanctions and Export Controls (Part III of III)

The Volkov Law Group on

DOJ’s new Corporate Enforcement Program is designed to bring certainty to the voluntary disclosure and cooperation process.  DOJ’s intent is clear — voluntary disclosure is likely to lead to a declination, reduced penalties...more

Pillsbury Winthrop Shaw Pittman LLP

DOJ Announces Shift in Approach to Prosecuting Corporate Crime

The Criminal Division’s revisions to white-collar enforcement policies seek a new balance between uncovering corporate crime and unencumbering American businesses....more

Katten Muchin Rosenman LLP

Think Compliance Got Easier? Think Again—DOJ’s New Era in White-Collar Enforcement (Part 2)

As discussed in our May 15th post, Matthew R. Galeotti, the Head of the Department of Justice’s (“Department”) Criminal Division, issued a memorandum on May 12th that highlights the core tenets of the Department’s enforcement...more

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