News & Analysis as of September 10, 2025

Disgorgement

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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
Understanding the DOJ's Recent Corporate Enforcement Policy Changes
Compliance into the Weeds: USRA Declination Case Study - Self-Disclosure Best Practices
2 Gurus Talk Compliance: Episode 47 – The Chaos Edition
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

Liberty Mutual Resolution Shows Route to Declination and Roadmap for Compliance Investments

ArentFox Schiff on 8/21/2025

The US Department of Justice (DOJ) declined to prosecute Liberty Mutual after the insurer voluntarily self-disclosed misconduct....more

DOJ Expands Availability of Declinations with Disgorgement for Corporations that Self-Disclose Misconduct

Bradley Arant Boult Cummings LLP on 1/31/2023

Earlier this month, DOJ updated its Corporate Enforcement Policy (CEP). Aimed at encouraging companies to voluntarily disclose unlawful conduct, the updated CEP gives greater opportunities to companies to avoid charges...more

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Self-Disclosure Requirements › FCPA Corporate Enforcement Policy (CEP) › Disgorgement

Liberty Mutual Resolution Shows Route to Declination and Roadmap for Compliance Investments

DOJ Expands Availability of Declinations with Disgorgement for Corporations that Self-Disclose Misconduct

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