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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

Hogan Lovells

SFO's new self-reporting guidance: A new deal or a departure from justice?

Hogan Lovells on

On 24 April 2025, the Serious Fraud Office (SFO) issued new guidance signalling a notable shift in its approach to corporate criminal enforcement. For the first time, the SFO has stated that if a company self-reports...more

Paul Hastings LLP

Keep Calm and Carry On: Thoughts on Recent Orders on FCPA Enforcement

Paul Hastings LLP on

What in the world is happening with enforcement of the Foreign Corrupt Practices Act (FCPA)? And what does the recent executive order (EO) and Department of Justice (DOJ) guidance mean for U.S. and global companies? Our view...more

BCLP

Crime-Fraud Exception Destroys Privilege for Communications Between Former CEO of Public Company and His Outside Lawyer

BCLP on

On February 7, 2025, the Second Circuit ruled that the crime-fraud exception would prevent the  former CEO of a public company from invoking attorney-client privilege to prevent an outside lawyer and his law firm from...more

WilmerHale

FCPA Year-in-Review: 2024 Developments and Predictions for 2025

WilmerHale on

Foreign Corrupt Practices Act (FCPA) enforcement activity increased overall in 2024, with a notable uptick in Department of Justice (DOJ) enforcement actions compared to 2023, despite a decrease in public Securities and...more

Foley Hoag LLP - White Collar Law &...

Anticorruption and FCPA Enforcement: Takeaways and Lessons Heading into 2025

This is the second in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for December 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

John Deere Reaches $9.9 Million Settlement with SEC over FCPA Violations

The Volkov Law Group on

The U.S. Securities and Exchange Commission (“SEC”) recently instituted proceedings against Deere & Company (“John Deere”), a leading global manufacturer of agricultural and heavy machinery, for multiple violations of the...more

McDermott Will & Schulte

DOJ Unveils Details of Corporate Whistleblower Awards Pilot Program

On August 1, 2024, the US Department of Justice’s (DOJ’s) Principal Deputy Assistant Attorney General of the Criminal Division, Nicole Argentieri, unveiled the highly anticipated details of DOJ’s Corporate Whistleblower...more

Akin Gump Strauss Hauer & Feld LLP

Federal Agency Settlements with Wells Fargo Illustrate Sanctions Risks Involving IT Systems

Key Points - On March 30, 2023, OFAC announced a settlement agreement with Wells Fargo for 124 apparent violations of three different sanctions programs (Iran, Syria and Sudan), all related to a legacy Wachovia Bank...more

Paul Hastings LLP

A Commitment to Transparency: Clarifying Key Enhancements to the U.S. Department of Justice’s Corporate Enforcement Guidance

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Since September 2022, the U.S. Department of Justice (“DOJ” or “the Department”) has made a number of announcements signaling notable changes to its U.S. corporate enforcement policies. These changes include key revisions to...more

Akin Gump Strauss Hauer & Feld LLP

New DOJ Focus on Executive Compensation in Resolving Criminal Investigations

Key Points - The DOJ recently announced several policy updates tethering resolution of criminal investigations to a company’s compensation and bonus programs. These updates include executive compensation focused...more

NAVEX

The Justice Department Steps Up Its Compliance Message

NAVEX on

The U.S. Justice Department unveiled new policies about how it will prosecute cases of corporate misconduct, offering new incentives for companies whose misconduct includes “aggravating circumstances” to step forward and...more

Society of Corporate Compliance and Ethics...

CEP Magazine - December 2022. Good things happen when enforcement listens

CEP Magazine - December 2022 - In September, U.S. Department of Justice (DOJ) Deputy Attorney General Lisa O. Monaco announced new guidelines the department will use in connection with criminal enforcement. Those...more

Foley Hoag LLP - White Collar Law &...

DOJ Updates Policies on Corporate Ethics and Compliance

Last week, Deputy Attorney General Lisa O. Monaco delivered remarks on corporate criminal enforcement, announcing revisions to DOJ’s policies for addressing corporate ethics and compliance matters. These changes reflect an...more

Jenner & Block

Deputy Attorney General Announces Revisions to DOJ's Corporate Criminal Enforcement Policies and Practices

Jenner & Block on

On September 15, 2022, Deputy Attorney General (DAG) Lisa Monaco issued a memorandum and delivered a speech, announcing several revisions to the Department of Justice's (DOJ)’s corporate criminal enforcement policies and...more

The Volkov Law Group

Deciphering FCPA Enforcement Trends

The Volkov Law Group on

In following the Justice Department and the Securities Exchange Commission FCPA enforcement actions, I am always reminded of the popular phrase — “reading the tea leaves.” (or “tasseography,” a fortune-telling method based on...more

The Volkov Law Group

What Can We Expect in Future FCPA Enforcement Actions?

The Volkov Law Group on

In the FCPA and white collar defense community, we have seen buckets and buckets of ink spilled on the coming wave of aggressive enforcement.  Justice Department officials have made so many statements about the “new” approach...more

Dorsey & Whitney LLP

DOJ Shows No Sign of Slowing Down Prosecution of Individuals Connected to FCA Cases

Dorsey & Whitney LLP on

Following a record year for False Claims Act (“FCA”) settlements and judgments in 2021, the Department of Justice (”DOJ”) continues to aggressively pursue the prosecution of not only corporations, but also the individuals...more

Jones Day

SEC Announces Proposed Amendments to Whistleblower Program Rules

Jones Day on

The proposed amendments to the rules governing the whistleblower program, if adopted, would reverse prior amendments and provide further and significant financial incentives for whistleblowers to report potential violations...more

Baker Donelson

Two Recent Corporate Pleas Affirm DOJ's Pledge to Crack Down on Criminal Enforcement

Baker Donelson on

Two recent criminal resolutions by the U.S. Department of Justice (DOJ) signal that DOJ is following through on Deputy Attorney General Lisa Monaco's recent pledge to crack down on corporate criminal enforcement....more

Patterson Belknap Webb & Tyler LLP

Takeaways from the SEC Division of Enforcement’s FY 2021 Report and Predictions for FY 2022

On November 18, 2021, the Securities and Exchange Commission (the “Commission”) released its Enforcement Results for fiscal year (“FY”) 2021, which spans from October 1, 2020 to September 30, 2021.  The Commission published...more

Bradley Arant Boult Cummings LLP

DOJ Announces New Policies Addressing White Collar Criminal Enforcement

Deputy Attorney General Lisa Monaco announced the Department of Justice’s new approach to prosecuting corporate crime, including policy changes that will reduce constraints on prosecutors and increase scrutiny on companies,...more

Bracewell LLP

DOJ's Torpedoes Are in the Water: Be Your Own Monitor, or One will Be Appointed for You

Bracewell LLP on

Last week, at a gathering of the nation’s top white collar criminal defense attorneys in Miami, Florida, Deputy Attorney General Lisa Monaco announced material changes to the way the Department of Justice will investigate,...more

Proskauer - Corporate Defense and Disputes

Over $1 Billion Whistleblower Awards Paid to Date by the SEC

Last week, the SEC announced accumulated awards of over $1 billion paid to 207 whistleblowers since its first award in 2012.  Over $500 million was awarded in fiscal year 2021 alone. The SEC crossed the billion-dollar...more

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