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Internal Investigations Department of Justice (DOJ) Corporate Counsel

McGlinchey Stafford

Former CEO Sentenced in Historic Insider Trading Case Under Rule 10b5-1

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On June 23, 2025, U.S. District Judge Dale S. Fischer of the Central District of California sentenced a former Chairman and CEO of a behavioral healthcare company to 42 months in federal prison. This conviction represents the...more

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

Holland & Knight LLP

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

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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

Fenwick & West LLP

Tech Companies Bear the Brunt of DOJ Push on Interlocking Directorates

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The United States Department of Justice (DOJ) announced last week that directors at several technology companies have resigned as a consequence of the agency’s renewed focus on overlapping board membership between...more

Butler Snow LLP

Company Cooperation Leads to Criminal Discovery

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When a company discovers that a crime may have been committed by individuals within the company, or is alerted by the government of that possibility, the company will often hire an outside law firm to conduct an internal...more

King & Spalding

Cooperation Credit and Attorney-Client Privilege: The Implications of Coburn

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Cognizant Technology’s Privilege Waiver - On February 1, 2022, the District of New Jersey ordered a company to produce internal investigation materials to two former executives indicted in connection with an alleged foreign...more

K&L Gates LLP

Federal Court Ruling Creates Possible Harbinger for Information Shared from Internal Investigations with the Government

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Introduction - Privilege assertions and waivers are a hot area for internal investigations and government proffers. One burning question centers around whether a party may claim privilege over materials that it furnished to...more

Bass, Berry & Sims PLC

Foreign Corrupt Practices Act Enforcement Update: Q1 2022

There have been a relatively limited number of U.S. Foreign Corrupt Practices Act (FCPA) enforcement actions in recent years. Nonetheless, two recent announcements (one resolution, one declination) by U.S. regulators...more

Health Care Compliance Association (HCCA)

[Event] Regional Healthcare Compliance Conference - January 28th, Orlando, FL

Looking for compliance training and networking in your area? HCCA’s Regional Healthcare Compliance Conferences offer practitioners convenient, local compliance training, including updates on the latest news in regulatory...more

McDermott Will & Schulte

[Webinar] Compliance AI + Smart Lawyering: Maximizing Data to Stay Ahead of the DOJ’s Key Enforcement Areas - July 20th, 12:00 pm...

The US Department of Justice (DOJ) now has more ammunition and resources than ever to use data analytics in their investigations. The convergence of better technology, increasingly usable data sets, and the ripe combination...more

Society of Corporate Compliance and Ethics...

[Virtual Event] 2021 Atlanta Regional Compliance & Ethics Conference - August 13th, 8:25 am - 4:30 pm EDT

Our Virtual Regional Compliance Conferences provide updates on the latest news in regulatory requirements, compliance enforcement, and strategies to develop effective compliance programs. Watch, listen, and ask questions from...more

Health Care Compliance Association (HCCA)

[Virtual Event] 2021 Regional Healthcare Compliance Conference - Orlando, FL - January 29th, 8:25 am - 5:30 pm EST

Our Virtual Regional Healthcare Compliance Conferences provide updates on the latest news in regulatory requirement, compliance enforcement, and strategies to develop effective compliance programs. Watch, listen, and ask...more

American Conference Institute (ACI)

[Virtual Event] 37th International Conference on the FCPA - December 2nd - 3rd, 9:00 am - 4:30 pm EST

The Annual Gathering for the Global Anti-Corruption Community - Exclusive Interview with President of Microsoft at FCPA DC - The world has reached an inflection point in which digital technology is being used as both a...more

Thomas Fox - Compliance Evangelist

Why the Board of Directors Need an Investigation Protocol

Many companies have an investigation protocol in place when a potential compliance or other legal issue arises. However, many Boards of Directors do not have the same rigor when it comes to an investigation, which should be...more

Society of Corporate Compliance and Ethics...

[Event] 2020 Virtual Chicago Regional Compliance & Ethics Conference - May 1st, Chicago, IL

Our Virtual Regional Compliance Conferences provide updates on the latest news in regulatory requirement, compliance enforcement, and strategies to develop effective compliance programs. Watch, listen, and ask questions from...more

Foley & Lardner LLP

Internal Investigations and Privileges: Two More Courts Rule

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Despite the global pandemic, the federal judiciary continues to issue rulings. In the last week, two courts provided guidance about when self-disclosures to the government waive the attorney-client privilege, underscoring the...more

Eversheds Sutherland (US) LLP

Legal privilege of corporate internal investigations under US law - 2019 caselaw update

Understanding the boundaries of legal privilege in corporate internal investigations is critical. When counsel, either internal or external, misunderstands these boundaries, the result can be disastrous....more

Faegre Drinker Biddle & Reath LLP

Important New Guidance for Companies Considering Voluntary Disclosures of Export Control and Sanctions Violations

On December 13, 2019, the U.S. Department of Justice’s National Security Division (NSD) issued important new policy guidance regarding voluntary disclosures of export control and sanctions laws violations. Among other things,...more

BCLP

SFO Corporate Co-operation Guidance – A flawed approach and a wasted opportunity

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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

BakerHostetler

Judge Rebukes Government for Outsourcing Internal Investigation of LIBOR Rigging Scheme

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On May 2, 2019, Judge Colleen McMahon of the Southern District of New York ruled that the government effectively outsourced a portion of its ongoing investigation of LIBOR manipulation at one financial institution (the Bank)...more

Thomas Fox - Compliance Evangelist

Walmart FCPA Enforcement Action: Part 1 – Introduction

The big one finally is resolved. The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced yesterday. This massive case came in with multiple documents, a long list of...more

A&O Shearman

DOJ Revises FCPA Corporate Enforcement Policy

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On March 8, 2019, the Department of Justice (“DOJ”) released a revised version of its FCPA Corporate Enforcement Policy (the “Policy”), which provides enforcement and practice guidance to DOJ prosecutors and was formally...more

Ward and Smith, P.A.

In-House Counsel Seminar Insights: Managing Internal Corporate Investigations While Preserving Privilege

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At this year’s Ward and Smith In-House Counsel Seminar, two of the firm’s white collar defense attorneys walked the attendees through a role-playing exercise designed to help them understand key nuances and risks that...more

Holland & Knight LLP

Petrobras Agrees to Pay More Than $1.8 Billion for Facilitating FCPA Violations

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• Four years ago, Brazilian authorities began Operation Car Wash, a wide-ranging and still ongoing corruption and money laundering investigation that has spanned 11 countries. • The fallout continues with a recent U.S....more

Thomas Fox - Compliance Evangelist

The NPA; The Petrobras FCPA Enforcement Action: Part III

This blog post concludes my multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. Today we consider the stunning result achieved by Petrobras –...more

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