Investigations, Corporate Misconduct, Cooperation

UK Serious Fraud Office Releases New Guidance on Self-Reporting, Cooperation and Deferred Prosecution Agreements

Skadden, Arps, Slate, Meagher & Flom LLP on 4/29/2025

On 24 April 2025, the Serious Fraud Office (SFO) released new guidance on corporate self-reporting, cooperation and deferred prosecution agreements (DPAs)....more

The Close-Out Debrief

Sheppard Mullin Richter & Hampton LLP on 2/1/2024

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

FINRA Issues Supplemental Guidance on Giving Credit for Extraordinary Cooperation

Vedder Price on 9/6/2019

On July 11, 2019, FINRA issued Regulatory Notice 19-23 to restate and supplement its prior guidance to member firms on the circumstances under which FINRA awards credit for providing "extraordinary cooperation" during an...more

Yates Memo Revisions Encourage Cooperation, but Fail Fully to Achieve a Common-Sense Approach to Civil Enforcement

Akin Gump Strauss Hauer & Feld LLP on 12/12/2018

• Recent Justice Manual changes roll back Yates memo requirements for corporations seeking cooperation credit in enforcement actions, including civil enforcement actions. • Corporations can now receive maximum cooperation...more

DOJ Revises Yates Memo and Relaxes Approach to Corporate Cooperation Credit

Blank Rome LLP on 12/12/2018

The Department of Justice (“DOJ”) announced that it is stepping back from its hard-line approach to corporate cooperation credit in which a corporation was not eligible for credit unless it disclosed all relevant facts about...more

Yates Memo Revised – DOJ Steps Back From All-or-Nothing Approach to Corporate Cooperation Credit

McGuireWoods LLP on 12/6/2018

The Justice Department’s revisions to the so-called “Yates Memo” continues a series of significant white collar enforcement policy changes. We hope this summary is helpful to businesses and their leaders in adjusting to these...more

Lessons Learned from the FCPA Pilot Program's First Six Months

Troutman Pepper Locke on 10/7/2016

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

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