News & Analysis as of

Self-Disclosure Requirements

Eversheds Sutherland (US) LLP

Tax Bytes: Week of July 28, 2025

Tax developments - IRS issues interim guidance to streamline LB&I audit procedures and promote alternative settlement programs - Significant updates from the IRS Large Business & International (LB&I) Division will take...more

Friling Law

Voluntary Self-Disclosure to OFAC: Legal Framework and Strategic Considerations

Friling Law on

Lawyers regularly advise clients on navigating the complex and evolving U.S. sanctions regime enforced by the Office of Foreign Assets Control (“OFAC”). When a business or individual becomes aware of a potential violation of...more

Husch Blackwell LLP

DOJ Declines to Prosecute Private Equity Firm After Self-Disclosure Related to Acquired Company

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Last year, the Department of Justice (DOJ) National Security Division (NSD) updated its Enforcement Policy for Business Organizations to include guidance related to voluntary self-disclosures in connection with acquisitions....more

NAVEX

Analyzing the U.S. Department of Justice’s New Whistleblower Rewards Programs and Revised Corporate Enforcement Policy

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The Department of Justice (DOJ) in recent weeks unveiled a newly created whistleblower rewards program within its Antitrust Division and an expanded whistleblower rewards program with the Criminal Division. The announcements...more

The Volkov Law Group

Interactive Brokers Settles with OFAC for $11.8 Million for Violations of Multiple Sanctions Programs

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced on July 15, 2025, that Interactive Brokers LLC (“IB”)—a globally active electronic brokerage firm headquartered in Greenwich,...more

Redgrave LLP

Maintaining Information Preservation and Management Vigilance in an Age of Apparent Reduced Law Enforcement

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Corporate legal departments are busy. They face new privacy regulations, ever-shifting trade policies, developments in artificial intelligence, and an unending stream of breaking news. It is difficult to keep up, and lately,...more

Phelps Dunbar

DOJ Expands Whistleblower Rewards to Include Immigration Violations

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Since May 12, when the U.S. Department of Justice (DOJ) announced policy changes to the Corporate Whistleblower Awards Pilot Program (CWAP), employers now face increased scrutiny and potential risks due to the DOJ’s recent...more

Blank Rome LLP

[Webinar] 180 Days of the Trump Administration—Quick Hits on Executive Orders, Actions, and Policies - July 17th - August 13th,...

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Blank Rome presents a new summer webinar series where our interdisciplinary team will unpack the most pressing legal, regulatory, and policy developments from the Trump Administration’s first 180 days. Each session offers...more

Paul Hastings LLP

DOJ’s M&A Safe Harbor Highlights Importance of Post-Close Due Diligence and Integration

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On June 16, the U.S. Department of Justice’s (DOJ’s or Department’s) National Security Division (NSD or Division) announced they had declined to prosecute the private equity firm White Deer Management LLC for violations of...more

Troutman Pepper Locke

DOJ’s Revised Self-Disclosure Policy May Offer Companies More Certainty

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Last month, the DOJ Criminal Division (Division) revised its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), introducing several potentially significant changes intended to further incentivize companies to...more

White & Case LLP

DOJ Declines to Prosecute Private Equity Firm after Post-Acquisition Voluntary Self-Disclosure of Sanctions and Export Control...

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In its first application of the policy on voluntary self-disclosures (“VSDs”) in connection with mergers and acquisitions (“M&A”), on June 16, 2025, the US Department of Justice’s (“DOJ”) National Security Division (“NSD”)...more

Rivkin Radler LLP

The Latest Refinements to DOJ’s White Collar Enforcement Policy

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Last month, the head of the Criminal Division of the U.S. Department of Justice (DOJ), Matthew R. Galeotti, issued a Memorandum outlining DOJ’s enforcement priorities and policies for prosecuting white-collar crime,...more

Society of Corporate Compliance and Ethics...

Understanding the DOJ's Recent Corporate Enforcement Policy Changes

On May 12, 2025 the head of the Criminal Division at the US Department of Justice issued a memo to all Criminal Division personnel with the subject: Focus, Fairness and Efficiency in the Fight Against White Collar Crime. To...more

Ropes & Gray LLP

DOJ’s New FCPA Playbook: “Time To Get To Work”

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On June 9, 2025, the U.S. Department of Justice (“DOJ” or the “Department”) issued the highly anticipated guidelines for investigations and enforcement of the Foreign Corrupt Practices Act (“FCPA”) (“FCPA Guidelines”),...more

Davies Ward Phillips & Vineberg LLP

A Strong Signal: AMF Adopts a Policy Supporting Self-Reporting and Cooperation

The Autorité des marchés financiers (AMF), the body responsible for enforcing Québec’s legislation concerning the financial sector, recently adopted a Self-Reporting and Cooperation Policy. The policy, adopted on May 20,...more

Morrison & Foerster LLP

DOJ Criminal Division Revises Its Corporate Enforcement Policy, Monitor Selection Policy, and Whistleblower Award Program

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

Cohen Seglias Pallas Greenhall & Furman PC

DOJ Increases Incentives to Self-Disclose with Revised Corporate Enforcement Policy

Earlier this month, the Department of Justice (DOJ) announced revisions to the Corporate Enforcement and Self Disclosure Policy (CEP). Under the new policy, announced by DOJ Criminal Division Head Matthew Galeotti, companies...more

Bradley Arant Boult Cummings LLP

SEC Enforcement Leadership Discusses New Priorities and Expectations

On May 20, 2025, as part of the annual “SEC Speaks” program, the leadership of the U.S. Securities and Exchange Commission’s (SEC) Division of Enforcement publicly discussed the enforcement priorities under new Chairman Paul...more

A&O Shearman

U.S. DOJ announces substantial strategic shifts in white-collar crime enforcement

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A new U.S. DOJ memo published on May 12 announces significant changes to the DOJ’s white-collar crime enforcement priorities, aligning the DOJ’s approach with the Trump Administration’s “America First” agenda. ...more

Carlton Fields

Shifting Priorities in White Collar Enforcement: May 2025 DOJ Memo and What It Means for Companies

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On May 12, 2025, the Department of Justice (DOJ) Criminal Division announced significant changes in its policies on investigating and prosecuting white collar crime, including a shift in focus toward several areas deemed to...more

K&L Gates LLP

Clearer Carrots and More Restrained Sticks: Key Updates to DOJ Corporate Enforcement Policies

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“The Criminal Division is turning a new page on white-collar and corporate enforcement.” So pronounced the head of the US Department of Justice (DOJ) Criminal Division, Matthew Galeotti, in a recent speech rolling out several...more

Cooley LLP

The DOJ’s Policy Shift to Incentivize Self-Reporting

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Earlier this week, the Department of Justice’s Criminal Division released three new documents on corporate misconduct, whistleblowers, compliance monitors, and enforcement priorities that outline significant changes to the...more

Bracewell LLP

DOJ Alert: New White-Collar Priorities and Stronger Incentives to Self-Report

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DOJ sets out new enforcement priorities for corporate and white-collar crime and emphasizes “focus, fairness and efficiency.”...more

Katten Muchin Rosenman LLP

Increased Clarity for White-Collar Clients: The Department of Justice Unveils its Revised Corporate Self-Disclosure Policy

What should U.S. businesses take from the Department of Justice’s (“DOJ”) revisions to its Corporate Enforcement and Voluntary Self-Disclosure Policy (“CEP”)? While DOJ has long promoted self-disclosure of wrongdoing as a...more

Fenwick & West LLP

DOJ Announces Key Revisions to Corporate Enforcement and Voluntary Self-Disclosure Policy

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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

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