Compliance Perspectives: The Antitrust Division’s Office of Decree Enforcement
Volatile Times in Vapor Intrusion Regulation: A Legal and Technical Update
Investment Management Roundtable Discussion – Regulatory and Enforcement Update
Podcast - Risk Management: Impact of Revised FCPA Policy on International Risk Management Programs
Podcast - Risk Management: Revised FCPA Corporate Enforcement Policy
Day 16 of One Month to More Effective Continuous Improvement-Voluntary Monitoring
Day 7 of One Month to Better Investigations and Report-How Investigations Inform Remediation
Day 22 of One Month to Better Compliance Through HR-10 Questions to Better Operationalize Compliance
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA
The decision for a company to self-disclose potential criminal misconduct to the U.S. Department of Justice (DOJ) is always complex. This is particularly true during periods of administration transitions when DOJ policies and...more
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
The US Department of Justice (DOJ) revised its Criminal Division Corporate Enforcement and Voluntary Disclosure Policy (CEP), outlining the benefits a company may earn by voluntarily self-disclosing misconduct, as well as the...more
In recently released updated guidance, the Antitrust Division (“Antitrust Division”) of the U.S. Department of Justice (“DOJ”) outlined how its prosecutors will assess corporate compliance programs when conducting criminal...more
A recent article in Law360 sparked a vigorous conversation among members of Pietragallo’s white collar practice group about the current state of the U.S. Department of Justice’s (DOJ) evolving emphasis on individual...more
On November 28–30, 2023, the American Conference Institute’s 40th International Conference on the Foreign Corrupt Practices Act (“FCPA”), held in Washington, D.C., brought together prosecutors, regulators, corporate...more
On October 4, 2023, Deputy U.S. Attorney General Lisa O. Monaco announced that the United States Department of Justice (DOJ) is implementing a new nationwide Mergers & Acquisitions Safe Harbor Policy (the “M&A Policy”)....more
Under a new U.S. Department of Justice ("DOJ") policy related to mergers and acquisitions ("M&A"), DOJ will decline to prosecute an acquiring company for misconduct by an acquired company where the acquiring company timely...more
No Longer Just a Matter of Paying the Fine and Moving On. Corporate settlement agreements used to be straightforward—pay the penalty and move on. Now, these resolutions rival complex business transactions, including...more
The Justice Department is on a marketing campaign – pushing a simple message. If your company commits misconduct, come in and confess to the Justice Department. To push this message, DOJ has tinkered with its Corporate...more
Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors. In a speech at Georgetown University Law Center on...more
In recent weeks, the Department of Justice has released key guidance in the form of a memorandum from Attorney General Garland regarding charging, pleas, and sentencing, in addition to an updated Corporate Enforcement Policy...more
On Jan. 17, AAG Polite announced “the first significant changes” to the CEP since 2017. The policy revisions will apply to all corporate criminal matters handled by the Criminal Division and offer companies “new, significant,...more
On January 17, 2023, Assistant Attorney General for the United States Department of Justice Kenneth A. Polite Jr. announced significant revisions to the Criminal Division’s Corporate Enforcement Policy (“CEP”). Four months...more
The U.S. Department of Justice (DOJ), through Assistant Attorney General Kenneth A. Polite Jr., announced on Jan. 17, 2023, "the first significant changes" to its Corporate Enforcement Policy (CEP) since 2017. The revisions...more
On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more
On March 8, 2019, the U.S. Department of Justice announced an important change to its Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy concerning one of the conditions — “appropriate retention of business...more
Assistant Attorney General Brian Benczkowski’s remarks provide important guidance for management and boards, and underscore the US Department of Justice’s commitment to prosecuting individuals for corporate misconduct....more
Sometimes I get to select the topics I blog on each week and sometimes it seems as if the topics select themselves. It looks like we will have a sports-themed week here on the FCPA Compliance and Ethics Blog. ...more
When it comes to a poster-child for corrupt organizations, there is very little competition that can eclipse Petrobas, the Brazilian state-owned oil and gas company. ...more
The Justice Department’s Antitrust Division maintains a robust criminal enforcement program fueled by the steady stream of leniency applicants. Since the 1990s, the Antitrust Division has trumpeted a successful leniency...more
There are two distinct themes in FCPA enforcement – the first is consistency, i.e., that some enforcement actions are relatively consistent across the board and, in the last five to ten years, the FCPA caseload has been...more
As the first-ever Compliance Counsel Expert at the United States Department of Justice (DOJ), Hui Chen served as exclusive consultant to the Fraud Section’s white-collar crime federal prosecutors. She reviewed corporate...more
With the close of 2017, FCPA enforcement continues as a major priority for the US Department of Justice. Notwithstanding fears and concerns that the new administration would turn its back on FCPA enforcement, the Justice...more
Next week marks the 40th anniversary of the Foreign Corrupt Practices Act – it became effective December 19, 1977. Deputy Attorney General Rod Rosenstein marked the occasion this month by providing an update on the FCPA Pilot...more