FCPA Compliance Report: 10 Core Principles for Effective Internal Investigations with Michelle Peirce
Compliance into the Weeds: Sanctions Compliance Failures: Lessons from Harman International and Interactive Brokers
Sanctions Compliance Failures: Lessons from Harman International and Interactive Brokers
Understanding the DOJ's Recent Corporate Enforcement Policy Changes
Compliance into the Weeds: USRA Declination Case Study - Self-Disclosure Best Practices
Understanding the Latest DOJ Changes to Corporate Prosecutions
The Justice Insiders Podcast: Self-Disclosure, Cooperation, and the Hazards of Knowing Too Little
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
The Presumption of Innocence Podcast: Episode 37 - Vintage or Trendsetting? The SDNY's Whistleblower Pilot Program
Episode 289 -- Justice, Commerce and Treasury Issue Joint Notice on Voluntary Disclosure
New DOJ Guidance Tightens Corporate Enforcement Strategy
Podcast - Risk Management: Revised FCPA Corporate Enforcement Policy
Day 29 of 31 Days to a More Effective Compliance Program
FCPA Compliance Report-Episode 346, Mike Skopets on Miller’s Summer 2017 FCPA Report
The Bribery Act: To Disclose or Not To Disclose?
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
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
In today’s regulatory landscape, dawn raids — surprise, on-the-spot government inspections — have become increasingly prevalent, especially in Europe, Asia, and South America, where regulatory scrutiny is intensifying. In the...more
1 The U.S. Attorney's Office for the Southern District of New York recently launched a criminal prosecution in connection with “a scheme to commit fraud in the carbon markets,” specifically that a company and its executives...more
The Department of Justice (DOJ) has sounded the alarm: an aggressive crackdown on corporate misconduct is imminent. With an enforcement program on the horizon, corporations must heed the warning and take proactive measures to...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
Last year, on February 22, 2023, the Department of Justice (DOJ) announced a corporate Voluntary Self-Disclosure (VSD) policy, which is applicable to all U.S. Attorney’s Offices, setting nationwide incentives for voluntary...more
2023 was a very active one for Department of Justice (DOJ or the “Department”) guidance, and that guidance had one clear theme: DOJ wants companies to voluntarily self-disclose their misconduct. To incentivize...more
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
Recent guidance from the US Department of Justice (DOJ) reflects its continued focus on corporate compensation structures to promote compliance. In the past few months, the DOJ has entered into settlement agreements that...more
U.S. Deputy Attorney General Lisa Monaco recently announced that the Department of Justice (DOJ) is adopting a new safe harbor policy to incentivize corporations to voluntarily self-disclose criminal misconduct discovered...more
The Environmental Crimes Section (“ECS”) of the United States Department of Justice (“DOJ”) Environment and Natural Resources Division (“NRD”) issued revisions to its Voluntary Self-Disclosure Policy which was issued in 1991...more
It is safe to assume that the United States Attorneys’ Offices Voluntary Self-Disclosure Policy announced on March 2, 2023 is intended to decrease wrongdoing and impose rehabilitation and recovery for victims. But...more
On March 2, 2023 and March 3, 2023, in a pair of speeches by Deputy Attorney General (DAG) Lisa Monaco and Criminal Division Assistant Attorney General (AAG) Kenneth Polite, the U.S. Department of Justice (DOJ) announced...more
On February 22, 2023, the Department of Justice announced a new Voluntary Self-Disclosure Policy (the Disclosure Policy) that now governs corporate prosecutions by US Attorney’s Offices (USAOs) nationwide. Building on a 2022...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 January 17, 2023, Assistant Attorney General (AAG) Kenneth Polite, Jr., delivered a speech announcing several important revisions to the Department of Justice (DOJ) Criminal Division’s Corporate Enforcement Policy (CEP)...more
New Requirements Place Onus on Corporations to Demonstrate more Compliance Capabilities to Receive Consideration from Prosecutors On September 15, 2022, Deputy Attorney General (“DAG”) Lisa Monaco spoke at New York...more
Late last year, the Department of Justice (DOJ) announced material changes to the way it intended to investigate, prosecute, and resolve corporate cases. The changes were aggressive, leading us to title our update “DOJ’s...more
On September 15, 2022, Deputy Attorney General Lisa Monaco announced significant changes to the U.S. Department of Justice’s (DOJ) approach to corporate criminal enforcement, including revised policies and an accompanying...more
On November 20, 2019, the US Department of Justice (DOJ) announced the latest revisions to the Foreign Corrupt Practices Act Corporate Enforcement Policy (the Corporate Enforcement Policy). The revised language provides...more