Moving Beyond the Usual Helpline Data
FCPA Compliance Report: 10 Core Principles for Effective Internal Investigations with Michelle Peirce
10 For 10: Top Compliance Stories For the Week Ending, July 26, 2025
Great Women in Compliance: The Compliance Influencer with Bettina Palazzo
Adventures in Compliance: Investigate Lessons from A Study in Scarlet
What the Board Should Be Asking About the Compliance Program
Common Scenarios Triggering False Claims Act Violations, Part 3: Claims and Investigations
False Claims Act Insights - The Art and Science of Corporate Compliance in Managing FCA Risk
An Ounce of Prevention: Keys to Understanding and Preventing AI and Cybersecurity Risks
Behavioral Health Compliance
The Justice Insiders Podcast: Using External Resources for Internal Investigations
Bank Investigations and Enforcement Actions: Lessons Learned — The Consumer Finance Podcast
The Justice Insiders Podcast: SEC Plays Chicken with Jarkesy
What Nonprofit Board Leadership Needs To Know About Internal Investigations
Compliance Series Part 3: Ensuring Compliance Programs are Effective
Compliance Programs Part 2: Designing a Successful Compliance Program
Compliance Programs Part 1: What is a Compliance Program and Why do Businesses Need One?
How to Combat Corporate Theft: Office Space - Hiring to Firing Podcast
All Things Investigations: Episode 28 - New French Anti-Corruption Investigative Guidance with Anne Gaustad and Bryan Sillaman
Investigative Power: Utilizing Self Service Solutions for Internal Investigations?
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
On March 26, 2024, the French Anti-Corruption Agency (AFA) published a guide on how to engage in corporate sponsorship and charitable donation activities while appropriately mitigating corruption risks (the Guide)...more
Investigations are stressful for an organization’s leadership. But what is often overlooked is that they are stressful for an organization’s employees as well. The need-to-know nature of internal investigations usually...more
A New Jersey federal court has ruled that a company’s self-disclosure of potential Foreign Corrupt Practices Act (FCPA) violations did not render the company a state actor, allowing evidence obtained by its internal...more
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
With developments in the investigations field, including the ongoing expansion of this field internationally, companies face an unprecedented level of scrutiny from outside parties, including government agencies, and are...more
Cooperation is frequently touted as the “secret sauce” that can help an issuer or individual facing potentially harsh regulatory scrutiny and sanctions for wrongful conduct mitigate the resolution of the action. Different...more
The changes include more focus on individual accountability, more holistic evaluation of prior corporate misconduct, and stricter corporate resolutions. On October 28, 2021, US Deputy Attorney General Lisa Monaco gave the...more
In 2019, the Criminal Division of the U.S. Department of Justice (DOJ) continued its efforts, begun a few years prior, to enhance transparency with respect to the DOJ's prosecutorial decision-making. In public statements, DOJ...more
The much heralded Corporate Co-operation Guidance published by the Serious Fraud Office recently offers little comfort to corporates struggling with the dilemma of whether to self-report wrongdoing. Instead it offers a...more
When Law No. 2016-1691 (Sapin II Law) created the convention judicaire d’intérêt public (CJIP), modeled after the American deferred prosecution agreement (DPA), it was feared that the existence of potentially dueling French...more
While white collar and healthcare counsel have long known that one of the best strategies to reducing risk in defending a False Claims Act (FCA) case is cooperation and execution of compliance actions, the Department of...more
The United States Department of Justice (DOJ) has issued new guidelines regarding cooperation and credit for self-disclosure specifically in False Claims Act matters. Such guidelines provide an overview of factors to be...more
In a November 29, 2018 speech, Deputy Attorney General Rod Rosenstein announced a softening of the US Department of Justice’s (DOJ) policy on giving credit for cooperation in corporate prosecutions. As memorialized in the...more
Yesterday, I considered four questions which the Department of Justice (DOJ) may ask Goldman Sachs. Today I want to consider what the company must show under the FCPA Corporate Enforcement Policy....more
• Deputy Attorney General Rod Rosenstein has announced a new U.S. Department of Justice (DOJ) policy to discourage government agencies from "piling on" duplicative corporate penalties. • Rosenstein signaled a desire for...more
On October 18, 2017, Kathleen McGovern, Senior Deputy Chief for the U.S. Department of Justice [“Department”] Criminal Division’s Fraud Section, spoke at the Association of Corporate Counsel annual meeting in Washington, DC....more
By now the whole world knows about Sally Yates. We are likely to see a lot more of her as a central figure in Congressional investigations. For some of us who deal with compliance investigations, Sally Yates was famous long...more
Yesterday I began an exploration of the General Cable Corporation (General Cable) Foreign Corrupt Practices Act (FCPA) enforcement action. It was settled with the DOJ via a Non-Prosecution Agreement (NPA) and the SEC via a...more
The guidance issued by the DOJ in connection with the Pilot Program and recent declinations state that disclosure, remediation and cooperation are essential to any favorable resolution with the government. Six months...more
On April 5, 2016, the Department of Justice unveiled a one-year pilot program designed to encourage companies to self-report violations of the Foreign Corrupt Practices Act (the FCPA). Built upon the Department’s September 9,...more
On April 5, 2016, the Department of Justice’s (“DOJ”) Fraud Section Chief, Andrew Weissmann, issued a memo (the “Weissmann Memorandum”) announcing a one-year Pilot Program that offers a carrot and stick approach to...more
This week, the Fraud Section of the Department of Justice (DOJ) announced a pilot program that extends additional “mitigation credit” to qualifying companies that “fully cooperate” in matters involving the Foreign Corrupt...more