News & Analysis as of

Personal Liability Compliance Corporate Misconduct

Rivkin Radler LLP

New York Sales Tax: When a Responsible Person Acts Irresponsibly

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Late last year, the Office of the State Comptroller (the “OSC”) estimated that sales and use tax receipts would increase by 2.3% in the SFY 2024-2025. The OSC also projected that collections from sales and use taxes would...more

BakerHostetler

Top Regulators Speak at the New York City Bar Association’s Compliance Institute

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In response to compliance officer personal liability concerns and increasing SEC regulations, Commissioner Peirce proposed the creation of a compliance advisory committee, which would bring together SEC regulators and...more

Venable LLP

DOJ Announces Pilot Program for Individual Voluntary Self-Disclosures

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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

Venable LLP

Part 1: Cooperation in Government Investigations and Voluntary Self-Disclosure: What to Expect After DOJ’s Latest Guidance

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​​​​​​​On September 15, Deputy Attorney General Lisa Monaco issued a department-wide memorandum containing revisions to the Justice Department’s (DOJ) corporate criminal enforcement policies (“the Memorandum”), including...more

Latham & Watkins LLP

US Deputy Attorney General Monaco Announces Revised Policies on Corporate Crime

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Updated DOJ policies will continue to focus on individual accountability and corporate recidivism, while aiming to provide additional incentives for voluntary self-reporting, foster greater transparency on use of monitors,...more

BakerHostetler

Deputy AG Lisa Monaco Announces Tough-on-Corporate-Crime Updates to DOJ Policies

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In prepared remarks delivered at New York University School of Law on Sept. 15, Deputy AG Monaco announced significant updates to the DOJ’s corporate criminal enforcement policies. Deputy AG Monaco’s announcement...more

WilmerHale

The Corporate Crime Advisory Group Has Spoken: DOJ Revises Corporate Criminal Enforcement Policies

WilmerHale on

On September 15, 2022, the Department of Justice (Department) released a memorandum revising several key aspects of its corporate criminal enforcement policies. The new policy, titled Further Revisions to Corporate Criminal...more

Womble Bond Dickinson

DOJ Announcements on Corporate Criminal Enforcement: Defining the Carrots and Sticks

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The Department of Justice (DOJ) has been touting revisions to its corporate criminal enforcement policies and signaling increased action for nearly a year. Yesterday, Deputy Attorney General Lisa O. Monaco formally announced...more

BakerHostetler

Attorney General Merrick Garland Emphasizes Criminal Corporate Enforcement and Individual Accountability

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On March 3, 2022, Attorney General Merrick B. Garland delivered a speech at the ABA Institute on White Collar Crime that underscored the Department of Justice’s (DOJ) commitment to prosecuting corporate crime and holding...more

Womble Bond Dickinson

“Carrots & Sticks”: Individual Accountability in Corporate Criminal Enforcement Remains a Top DOJ Priority

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On March 3, 2022, at the 37th Annual American Bar Association Criminal Justice Section National Institute on White Collar Crime in San Francisco, Attorney General Merrick B. Garland emphasized that “the prosecution of...more

Holland & Knight LLP

AG Merrick Garland: DOJ Prioritizing Prosecution of Individuals in White Collar Crime

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In remarks to the American Bar Association (ABA) Institute on White Collar Crime on March 3, 2022, Attorney General Merrick Garland underscored the U.S. Department of Justice's (DOJ) renewed emphasis on corporate...more

Tucker Arensberg, P.C.

2022 Federal Compliance Enforcement Outlook

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There is almost universal agreement regarding predictions for 2022 federal enforcement in the following areas: ..The use of fraudulently obtained COVID relief funds in both healthcare and in general, but specifically as...more

Latham & Watkins LLP

Senior US DOJ Official Sets Forth New Priorities for Pursuing Corporate Crime

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The priorities will impact non-US companies who may face a US DOJ with a renewed emphasis on combating corporate crime. In a recent speech that has garnered significant attention, the Deputy Attorney General of the...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Announces Revised FCPA Corporate Enforcement Policy

In a speech yesterday at the 34th International Conference on the Foreign Corrupt Practices Act, U.S. Deputy Attorney General Rod Rosenstein announced the Department of Justice’s (DOJ) revised Foreign Corrupt Practices Act...more

NAVEX

4 Questions About the Yates Memo’s First Year

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The release of the so-called Yates Memo in fall 2015 shook the compliance world. U.S. Deputy Attorney General Sally Q. Yates made it clear that federal regulators would look to combat corporate misconduct by “seeking...more

McGuireWoods LLP

SEC Enforcement Chief Andrew Ceresney Discusses CCO Liability

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On November 4, 2015, Andrew Ceresney, director of the Securities and Exchange Commission’s (SEC’s) Division of Enforcement (Enforcement Division), delivered the keynote address at the 2015 National Conference of the National...more

Fenwick & West LLP

You’re the Man—Government Targets Individuals in FCPA Cases

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The government has increasingly focused its FCPA enforcement firepower on individuals. On August 31, a Russian official living in Maryland pled guilty to conspiracy to commit money laundering in connection with arranging $2...more

NAVEX

Despite Criticism, DOJ’s New Policy On Internal Investigations Could Be a Good Thing

NAVEX on

While naysayers believe the Department Of Justice's (DOJ’s) memo is going to result in major complications and headaches for companies experiencing government investigations, ethical companies are unlikely to be affected much...more

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