Popular, Department of Justice (DOJ), Corporate Misconduct

FCPA Enforcement Is Back with a New Enhanced Focus on Protecting US Business Abroad, National Security, Individuals and (of...

BakerHostetler on 6/13/2025

U.S. Department of Justice (DOJ) Deputy Attorney General Todd Blanche issued a memorandum on June 9 (the Memo), announcing DOJ will resume enforcement of the Foreign Corrupt Practices Act (FCPA) after its brief hiatus....more

DOJ Streamlines Voluntary Self-Disclosure Policy for More Favorable Corporate Criminal Resolutions

Wilson Sonsini Goodrich & Rosati on 6/4/2025

When a company detects potential criminal misconduct, it must decide whether to self-disclose the misconduct to the U.S. Department of Justice (DOJ). This decision—while always complicated—is even more difficult during...more

DOJ Unveils New Plan for White-Collar Crime and Corporate Enforcement

McDermott Will & Schulte on 5/15/2025

The US Department of Justice’s (DOJ’s) current approach to corporate criminal enforcement has come into focus with the issuance of a new White-Collar Enforcement Plan and several revised policy documents. The changes, which...more

Top 10 International Anti-Corruption Developments for December 2024

Morrison & Foerster LLP on 1/14/2025

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

5 Trends Shaping Whistleblower Regulations in 2025

Mitratech Holdings, Inc on 11/18/2024

In 2025, whistleblower regulations are poised for major evolution, reflecting a renewed commitment to transparency and accountability. The Ethics and Compliance Initiative (ECI) 2023 survey revealed a startling statistic:...more

DOJ’s New Whistleblower Program: Filling in the Gaps and Encouraging Tips (Part II of II)

The Volkov Law Group on 8/21/2024

DOJ is joining the whistleblower reward sweepstakes in a big way. While the SEC has been grabbing headlines for its whistleblower reward program since 2010, DOJ now wants a piece of the action. DOJ cited gaps that exist...more

Off to the Races: DOJ Offers New Incentives for Whistleblowers and Companies to Report Misconduct

Paul Hastings LLP on 8/9/2024

Earlier this year, as described in a previous client alert, the Department of Justice (“DOJ”) Criminal Division announced a landmark pilot program to pay monetary awards to whistleblowers (the “Program”). At that time, Deputy...more

"Please Pay No Attention to the Microphone:” DOJ Announces New Program Offering Protections to Criminal Whistleblowers

Polsinelli on 5/2/2024

On April 15, 2024, the Criminal Division of the U.S. Department of Justice (“DOJ”) released new guidance relating to a Pilot Program on Voluntary Self-Disclosures for Individuals, promising to offer protection from criminal...more

DOJ launches whistleblower pilot program and cracks down on artificial intelligence misuse

Ballard Spahr LLP on 3/19/2024

Following a year of new DOJ policies and guidance designed to incentivize companies to self-report misconduct and to cooperate with government investigations, the DOJ has added a new pilot whistleblower rewards program. In...more

DOJ Announces New Programs, Continued Focus on Corporate Conduct & Other Highlights from the ABA 39th Annual National Institute on...

Vedder Price on 3/15/2024

Fireside Chat with Attorney General Merrick Garland - A highlight of the conference was a fireside chat with Attorney General Merrick Garland. AG Garland first discussed the important lead the United States has with...more

Risk & Compliance as a Strategic Imperative for the Board

NAVEX on 2/20/2024

In an era marked by heightened global regulatory scrutiny and enforcement, the landscape of risk and compliance is undergoing an evolution making the strategic imperative for effective, risk-based compliance initiatives...more

How DOJ's Safe Harbor Policy Rewards Honesty Within M&A Deals

DarrowEverett LLP on 1/23/2024

Be you a merger and acquisition attorney, corporate compliance officer, or counsel to an acquiring entity or target entity, you should review the Department of Justice’s new Merger and Acquisition Safe Harbor Policy...more

A View from Abroad: Unpacking DOJ’s M&A Safe Harbor Policy, Part II

White & Case LLP on 12/4/2023

On October 4, 2023, United States Deputy Attorney General (DAG) Lisa Monaco announced a new Department of Justice (DOJ) Mergers & Acquisitions Safe Harbor policy that encourages companies to self-disclose criminal misconduct...more

The Subtle but Significant Shift at U.S. Justice Department

NAVEX on 11/30/2023

In October, deputy attorney general Lisa Monaco made headlines when she announced a new leniency policy at the U.S. Justice Department for companies that disclose compliance violations discovered during mergers and...more

U.S. DOJ’s New Safe Harbor Policy: Conducting Enhanced M&A Due Diligence

Ankura on 11/20/2023

Last month, U.S. Deputy Attorney General Lisa O. Monaco announced a new Safe Harbor Policy for voluntary self-disclosure (the “Policy”) made in connection with merger and acquisition activity. The Policy is intended to bring...more

Tri-Seal Compliance Note: Voluntary Self-Disclosure of Potential Violations

Akin Gump Strauss Hauer & Feld LLP on 8/7/2023

On July 26, 2023, the departments of Commerce, Justice and the Treasury issued their second ever to date “Tri-Seal Compliance Note” (the “Note”). It describes expectations for the voluntary disclosure of sanctions, export,...more

Three Things to Consider After DOJ’s Announcement on New Corporate Messaging Policy

Orrick, Herrington & Sutcliffe LLP on 3/17/2023

The Department of Justice recently announced new policy changes relating to its evaluation of corporate communication policies. The DOJ’s new guidance makes clear that, when evaluating the adequacy of corporate compliance...more

Corruption, Crime, and Compliance - DOJ’s Compliance Frontier: Incentives and Disincentives

Thomas Fox - Compliance Evangelist on 2/20/2023

On this episode of the Crime, Corruption, and Compliance podcast, host Michael Volkov discusses the Department of Justice’s recent focus on incentives and disincentives as part of an effective ethics and compliance program....more

A Look Ahead into Corporate Enforcement in the Biden Administration

WilmerHale on 11/10/2021

Just one year after President Biden’s election, senior administration officials have signaled in public remarks that the federal government will amplify enforcement pressure on corporations and their employees through...more

Novartis and Alcon Settle FCPA Violations for $345 Million (Part I of III)

The Volkov Law Group on 6/29/2020

Even during this difficult time of the pandemic, economic uncertainty and social unrest, the Justice Department and the SEC have concluded a major FCPA enforcement action....more

Walmart FCPA Settlement Shines Light On Corporate Compliance Programs

Burr & Forman on 6/21/2019

June 20, 2019 – Walmart (NYSE: WMT) and its subsidiary, WMT Brasilia, agreed to a combined criminal penalty and disgorgement of $282M, together with WMT’s criminal guilty plea and undertakings in an NPA, to reach a global...more

A Dialogue With Corporate Counsel: Skadden’s Eighth Annual Pharmaceutical and Medical Device Seminar

Skadden, Arps, Slate, Meagher & Flom LLP on 12/13/2018

On October 30, 2018, Skadden hosted its Eighth Annual Pharmaceutical and Medical Device Enforcement and Litigation Seminar in New York City, which focused on U.S. enforcement issues faced by companies throughout the industry....more

Goldman Sachs and the 1MDB Criminal Prosecutions

The Volkov Law Group on 11/6/2018

The 1Malaysia Development Berhad scandal (“1MDB scandal”) has been making headlines for the past few years. The turning point for US prosecutors was the cooperation of Malaysian law enforcement and the corruption allegations...more

Day 29 of 31 Days to a More Effective Compliance Program

Thomas Fox - Compliance Evangelist on 1/29/2018

One new and different item was laid out in the Evaluation of Corporate Compliance Program, supplementing the Ten Hallmarks of an Effective Compliance Program from the 2012 FCPA Guidance. This was the performance of a root...more

Day 18 of One Month to More Effective Continuous Improvement-Email Sweeps for Continuous Improvement

Thomas Fox - Compliance Evangelist on 8/24/2017

Ongoing monitoring is not limited to the financial component of compliance. Another approach to review emails as both a preventative and detection program through the technique of email sweeps. The concept is straightforward;...more

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