Compliance into the Weeds: Boeing, a NPA and the End of Monitors
Understanding the Whistleblower Pilot Program in the Southern District of New York
Episode 295 -- Deep Dive into the Albemarle DOJ and SEC FCPA Settlements
Federal Monitorships and Making Them Work
Salvador Dahan on the Journey of Petrobras
Compliance Into The Weeds: DAG Announces Changes in Enforcement Priorities
FCPA Compliance and Ethics Report-Episode 134, Judge Rakoff, Judge Leon and their comments on DPAs, with the FCPA Professor
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA
On May 12, 2025, the Criminal Division of the U.S. Department of Justice (DOJ) revised its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) and Corporate Whistleblower Awards Pilot Program (Whistleblower...more
On May 12, 2025, the Head of the Department of Justice’s (DOJ) Criminal Division, Matthew Galeotti, announced a new white collar enforcement plan in a memorandum entitled “Focus, Fairness, and Efficiency in the Fight Against...more
Share on Twitter Print Share by Email Share Back to top On May 12, 2025, the U.S. Department of Justice (DOJ) announced revisions to its Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP). (See...more
The Department of Justice’s (DOJ) recent announcement that it would decline to prosecute a self-reported criminal export control violation demonstrates the continuing importance of prompt, voluntary self-disclosure (VSD) and...more
Over the past two years, the Department of Justice (DOJ or the Department) has actively incentivized companies to voluntarily self-disclose potential civil and criminal violations. For example, in 2023, in the criminal...more
For years, Department of Justice officials have stressed how important chief compliance officers are as the first line of defense in fighting corporate crimes. While that’s true, compliance programs now have a competitor in...more
The Department of Justice (DOJ) has announced a pilot program to encourage potential whistleblowers to report criminal activity and cooperate with government investigations in exchange for substantial monetary payouts in the...more
Introduction: On April 15, 2024, the Department of Justice’s (DOJ) Criminal Division announced a new Pilot Program on Voluntary Self-Disclosure for Individuals. Under this program, individuals who voluntarily disclose certain...more
In a bold move, the U.S. Department of Justice (DOJ) launched a pilot program designed to encourage corporate executives to disclose information about financial misconduct within their organizations. Through this initiative,...more
The Department of Justice’s Criminal Division (DOJ) recently announced a Pilot Program on Voluntary Self-Disclosures for Individuals (the Individual VSD Pilot Program or Pilot Program), which allows certain individuals...more
On April 15, 2023 Nicole Argentieri, Principal Deputy Assistant Attorney General and the Head of the U.S. Department of Justice’s (“DOJ’s”) Criminal Division, announced a new voluntary self-disclosure program for individuals...more
On April 15, 2024, the Department of Justice (DOJ) criminal division announced a new pilot program designed to reward individuals with non-prosecution agreements (NPAs) who voluntarily self-disclose "actionable, original...more
“Call us before we call you.” With this message, on January 10, 2024, the Southern District of New York announced the SDNY Whistleblower Pilot Program (Pilot Program), which seeks to encourage individual participants in...more
As previously reported, the Department of Justice (DOJ) has announced comprehensive corporate criminal enforcement policy changes utilizing both “carrots” and “sticks” to encourage companies to voluntarily self-disclose...more
Over the past several blog posts, I have been exploring the Albemarle FCPA enforcement action. We have explored in some detail the DOJ Non-Prosecution Agreement (NPA) and the SEC Administrative Order(Order). In this final...more
Voluntary self-disclosure is a valuable remediation measure for companies who identify their own potential violations of U.S. sanctions, export controls, and other national security laws....more
On April 29, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced two settlements of potential civil liability with two companies over their apparent violations of its regulations. The...more
In a development that could significantly affect how companies deal with possible export control and sanctions violations, the Department of Justice (“DOJ”) recently revised its policy regarding voluntary disclosure of trade...more
The past year was consequential for FCPA enforcement in numerous respects, including blockbuster penalties, new policy initiatives, and the SEC’s first DPA with an individual for FCPA violations. In April 2016, the DOJ’s...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
Yesterday, I began a three-part series on how two companies, which came to Foreign Corrupt Practices Act (FCPA) grief in China for bribery within their Chinese business units, received the rather stunning results of both Non...more