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Self-Disclosure Requirements Enforcement Actions Corporate Governance

NAVEX

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

NAVEX on

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

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

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

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

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

Akin Gump Strauss Hauer & Feld LLP

DOJ’s Criminal Division Turns Page on White Collar Crime—But Keeps One Foot in the Past

On May 12, 2025, the DOJ announced a new “white-collar enforcement plan” identifying new corporate enforcement priorities and aiming to promote greater focus, fairness and efficiency in prosecuting corporate misconduct. In a...more

Alston & Bird

Enter the Matrix: CFTC’s New Framework for Self-Reporting, Cooperation, and Remediation

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Our White Collar, Government & Internal Investigations Group analyzes new enforcement guidance from the Commodity Futures Trading Commission (CFTC) that aims to incentivize self-reporting of potential violations....more

Society of Corporate Compliance and Ethics...

Understanding the Latest DOJ Changes to Corporate Prosecutions

On November 22, 2024, then Principal Deputy Assistant Attorney General Nicole Argentieri recapped the changes made during the Biden Administration in enforcement policies and announced a few new ones. To better understand...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Launches Corporate Whistleblower Awards Pilot Program and Announces a New Incentive for Self-Reports

On August 1, 2024, the Department of Justice’s Criminal Division launched the Corporate Whistleblower Awards Pilot Program (the Program), following up on its announcement in March 2024 of a plan to offer whistleblower awards....more

Jenner & Block

Client Alert: DOJ Continues Its Trend of Strengthening Incentives to Report Corporate Misconduct

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Just over a month after Deputy Attorney General Lisa Monaco announced the upcoming launch of the Department of Justice’s whistleblower rewards program, the DOJ Criminal Division unveiled its newest program to incentivize...more

Foley Hoag LLP - White Collar Law &...

Anticorruption Enforcement and the Foreign Corrupt Practices Act: Trends to Track in 2024

This is the seventh in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more

Bass, Berry & Sims PLC

Foreign Corrupt Practices Act Update: Considerations Around Voluntary Disclosures

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In September 2022, Deputy Attorney General Lisa Monaco outlined the Department of Justice (DOJ) approach to enforcing corporate misconduct and directed agencies to review existing voluntary self-disclosure policies or, if...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Leverages the Private Sector To Achieve Enforcement Goals

Key Points - - In the latest round of additions to the DOJ’s programs to incentivize voluntary self-disclosure of wrongdoing by corporations, the DOJ has rolled out new policies that outline concrete incentives for...more

American Conference Institute (ACI)

[Event] 40th International Conference on the FCPA - November 28th - 30th, National Harbor, MD

Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more

Sheppard Mullin Richter & Hampton LLP

DOJ Continues to Discuss Updates to Compliance Program Guidance and Corporate Enforcement Policies

As the spring conference season winds down, there was one topic that remained top of mind. At the Food and Drug Law Institute (“FDLI”)’s Annual Conference on May 17-18, 2023, the U.S. Department of Justice (“DOJ”)’s Consumer...more

J.S. Held

Building a Strong Compliance Program That Meets the Revised DOJ Corporate Enforcement Policy

J.S. Held on

A corporate compliance program can be thought of as a magnet that brings a company’s compliance efforts together. It is an operational program, not simply a code of expected ethical behavior. An effective compliance...more

Morgan Lewis

DOJ Announces Compensation Clawback Pilot Program, Changes to Corporate Compliance Program Evaluation Criteria

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The US Department of Justice recently announced a compensation clawback pilot program as well as changes to the corporate compliance program evaluation criteria in the latest of a flurry of policy updates....more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Implements Voluntary Self-Disclosure Policy for US Attorneys’ Offices

On February 22, 2023, the Department of Justice (DOJ) adopted a new policy that establishes a national standard for voluntary self-disclosure credit in corporate criminal enforcement actions brought by U.S. Attorneys’ Offices...more

Wiley Rein LLP

New Year, New Compliance Challenges: Good Reasons to Spruce up Your Compliance Program in 2023

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At the start of 2023, we made a number of corporate criminal enforcement predictions. With 2023 launched, we are circling back to highlight initiatives that government contractors may wish to consider undertaking as...more

McDermott Will & Emery

DOJ Formalizes Guidelines, Incentives for Corporate Self-Disclosure Through New Policy Directive for US Attorneys’ Offices

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On February 24, 2023, the US Department of Justice (DOJ) rolled out a corporate self-disclosure policy (the Policy) to be applied by all 93 US Attorneys’ Offices throughout the country. The details of the Policy—which...more

Foley Hoag LLP

CEP Revisions Incentivize “Extraordinary” Corporate Cooperation

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Earlier in January 2023, the U.S. Department of Justice (DOJ) announced revisions to its Corporate Enforcement Policy (CEP) under the Foreign Corrupt Practices Act (FCPA) for the first time since 2017. In his speech...more

Wiley Rein LLP

DOJ’s “Carrot” Approach to Corporate Enforcement Policy (But Read the Fine Print)

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Last Tuesday, the Department of Justice (DOJ) announced the most recent modifications to its Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) in an effort to further encourage companies to...more

Paul Hastings LLP

Bigger Carrots, More Sticks? DOJ Revises Its Corporate Criminal Enforcement Policy

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On January 17, 2023, Assistant Attorney General Kenneth A. Polite, Jr. (“AAG Polite”) announced several key revisions to the Department of Justice (“DOJ”) Criminal Division’s Corporate Enforcement Policy (the “CEP”) governing...more

Lowenstein Sandler LLP

DOJ Revamps Incentives for Companies to ‘Come Forward, Cooperate, and Remediate’

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On January 17, 2023, the Department of Justice (DOJ), Criminal Division, announced it has reassessed and strengthened its Corporate Enforcement Policy, which applies to all corporate criminal matters (including Foreign...more

Morrison & Foerster LLP

In Revised Corporate Enforcement Policy, DOJ Increases Incentives for Voluntary Self-Disclosure and Cooperation

On January 17, 2023, the Assistant Attorney General (AAG) for the Criminal Division of the U.S. Department of Justice (DOJ), Kenneth Polite, Jr., announced that DOJ had made “significant changes” to its Corporate Enforcement...more

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