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
In an advisory announced February 25, 2025, the Division of Enforcement of the Commodity Futures Trading Commission (CFTC or Commission) announced a new regime for assessing cooperation credit in determining fines in the...more
The Commodity Futures Trading Commission (CFTC) recently issued a significant Enforcement Advisory detailing how companies and individuals can earn Mitigation Credit....more
On October 10, 2024, Attorney General Merrick Garland announced that TD Bank agreed to pay over $1.8 billion in penalties to resolve the U.S. Department of Justice’s (DOJ) investigation into money laundering and Bank Secrecy...more
Companies and their executives can reduce Department of Justice (DoJ), OFAC, and Commerce Department risks (and liability) by understanding and respecting the relationship between economic sanctions, voluntary...more
Recent Department of Justice (“DOJ” or “Department”) activity on bribery in Mexico and Latin America sends a warning and provides a roadmap to companies doing business there. By following the roadmap, companies may escape...more
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
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
Continuing its focus on incentivizing prompt and voluntary self-disclosure of criminal misconduct, Deputy Attorney General Lisa Monaco announced earlier this month a new U.S. Department of Justice (DOJ) Safe Harbor Policy...more
The United States Department of Justice (DOJ) recently announced a new department-wide Mergers & Acquisitions Safe Harbor Policy that protects acquiring companies that self-disclose criminal misconduct discovered at an...more
In an important policy announcement aimed at rewarding robust due diligence and compliance programs, DOJ announced that acquiring companies that promptly and voluntarily disclose criminal misconduct discovered at the acquired...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
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
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 13, 2019, the US Department of Justice (DOJ) announced a revised Export Control and Sanctions Enforcement Policy for Business Organizations (Revised EC/S Policy), clarifying its prior guidance on voluntary...more
On December 13, 2019, the US Department of Justice (DOJ) issued an update to its 2016 guidance regarding enforcement in export control and sanctions investigations of businesses. The updated policy now offers voluntary...more
On May 6, 2019, the Justice Department issued new policies establishing how defendants in False Claims Act (FCA) matters can earn credit for voluntary self-disclosure, cooperation, and remediation, possibly reducing what...more
When DOJ announced its FCPA Corporate Enforcement Policy in 2017 (later expanded to all corporate criminal defendants), defense lawyers expressed concern about a provision buried within what it meant to provide “timely and...more
I conclude my five-part series on the soft skills a Chief Compliance Officer (CCO) needs to employ when working through the remediation component of a potential Foreign Corrupt Practices Act (FCPA) compliance violation. I...more
By now the whole world knows about Sally Yates. We are likely to see a lot more of her as a central figure in Congressional investigations. For some of us who deal with compliance investigations, Sally Yates was famous long...more
The extension of the program — which emphasizes voluntary self-disclosure of FCPA violations, raises considerations for corporate entities and individual executives. The Department of Justice (DOJ) recently announced...more
The Justice Department has raised the stakes on anti-corruption compliance. In other words, DOJ prosecutors expect companies to have more sophisticated and mature compliance programs. If a company walks into the Justice...more
Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more
On April 5, 2016, the Department of Justice unveiled a one-year pilot program designed to encourage companies to self-report violations of the Foreign Corrupt Practices Act (the FCPA). Built upon the Department’s September 9,...more