News & Analysis as of

Self-Disclosure Requirements New Guidance

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

Ropes & Gray LLP

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

Ropes & Gray LLP on

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

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

Cooley LLP

The DOJ’s Policy Shift to Incentivize Self-Reporting

Cooley LLP on

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

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

K2 Integrity

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

K2 Integrity on

On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

Foley & Lardner LLP

“Let’s Talk Compliance”: OIG’s General Compliance Program Guidance: How to Refresh Compliance Programs

Foley & Lardner LLP on

Editor’s Note: PYA and Foley & Lardner hosted the 6th Annual “Let’s Talk Compliance” two-day Virtual Conference on January 18 and 19, 2024. Panelists included Foley & Lardner attorneys and PYA experts. The event was hosted by...more

Ankura

U.S. DOJ’s New Safe Harbor Policy: Conducting Enhanced M&A Due Diligence

Ankura on

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

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

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Announces Safe Harbor Policy for Voluntary Self-Disclosures Related to Mergers & Acquisitions

In the U.S. Department of Justice’s (DOJ’s) latest effort to promote voluntary self-disclosure of corporate misconduct by companies, Deputy Attorney General (DAG) Lisa Monaco has announced guidance regarding a new safe harbor...more

Ballard Spahr LLP

“Tri-Seal” Compliance Notice: U.S. Authorities Release Joint Guidance on Voluntary Self-Disclosure of Potential Sanctions and...

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On July 26, the Department of Commerce, the Department of the Treasury, and the Department of Justice released a joint compliance notice (the “Compliance Notice”) updating and summarizing each agency’s position regarding the...more

Snell & Wilmer

CFIUS Releases Guidance Concerning Enforcement and Penalty Actions

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On October 20, 2022, the Committee on Foreign Investment in the United States (“CFIUS”) issued the “CFIUS Enforcement and Penalty Guidelines” (the “Guidelines”). These are the first-ever Guidelines issued by CFIUS which is a...more

Holland & Knight LLP

CFIUS Enforcement and Penalty Guidelines Enhance Transparency for Cross-Border Dealmakers

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The Committee on Foreign Investment in the United States (CFIUS) released the first-ever CFIUS Enforcement and Penalty Guidelines (Guidelines) on Oct. 20, 2022, providing the public a roadmap describing three categories of...more

Troutman Pepper Locke

New DOJ Guidance Tightens Corporate Enforcement Strategy

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Join Troutman Pepper White Collar and Government Investigation Partners Callan Stein, Miranda Hooker, and Allison DeLaurentis for a podcast discussion on the DOJ’s updated guidelines regarding corporate criminal enforcement....more

Bracewell LLP

DOJ to Companies: If You Step Up & Own Up, You Might Not Have to Pay Up

Bracewell LLP on

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

Jones Day

New Guidance for Dutch Prosecutor on the Investigation and Prosecution of Foreign Corruption

Jones Day on

On October 1, 2020, the new Instruction on the Investigation and Prosecution of Foreign Corruption for the Dutch Public Prosecution Service ("DPPS") entered into force, indicating certain factors that play a role in...more

Skadden, Arps, Slate, Meagher & Flom LLP

Transatlantic Approach on Corporate Cooperation: How Newly Issued French and UK Guidance Compare to US Practices

As widely anticipated, French and U.K. regulators recently published guidance detailing their expectations for corporate cooperation in enforcement investigations. Both sets of guidance demonstrate further alignment of those...more

McDermott Will & Emery

International Legal Highlights - July 2019

FCPA UPDATES FOR GLOBAL COMPANIES - In recent months, the US Department of Justice (DOJ) has issued important guidance for global companies on corporate compliance programs and the Foreign Corrupt Practices Act (FCPA)...more

McDermott Will & Emery

DOJ Preserves Its Options in Cooperation Credit Guidance

McDermott Will & Emery on

DOJ recently announced the release of formal guidance on how civil attorneys can award “cooperation credit” to defendants who cooperate with DOJ during a False Claims Act investigation. This formal policy provides some new...more

Ruder Ware

The Federal Government Really Wants You to Self Disclose

Ruder Ware on

The Department of Justice (DOJ) along with other health care fraud enforcement agencies, continue to send strong signals that they want businesses to police themselves for potential compliance issues and self-disclose where...more

PilieroMazza PLLC

Justice Department Issues New False Claims Act Guidance on Cooperation Credit That May Reduce FCA-Defendant Liability

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Last week, on May 7, 2019, the U.S. Department of Justice (“DOJ”) announced the issuance of formal guidance to clarify the manner in which the DOJ allocates credit to defendants who cooperate with government investigations in...more

Harris Beach Murtha PLLC

DOJ Issues Guidelines for Cooperation Credit Specifically as to False Claims Act Matters

The United States Department of Justice (DOJ) has issued new guidelines regarding cooperation and credit for self-disclosure specifically in False Claims Act matters. Such guidelines provide an overview of factors to be...more

Perkins Coie

Getting Cooperation Credit Under New DOJ False Claims Act Guidance

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The U.S. Department of Justice (DOJ) released long awaited guidance last week on how it will evaluate and credit self-disclosures and cooperation in False Claims Act (FCA) cases. The new guidelines, codified in the DOJ’s...more

Faegre Drinker Biddle & Reath LLP

New DOJ Guidance Aims to Incentivize Corporate Cooperation in False Claim Act Matters

On May 7, 2019, the Department of Justice issued important guidance on the type of cooperation that is eligible for credit in False Claim Act (FCA) investigations. The guidance, formally codified in the Justice Manual Section...more

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