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
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
On December 6, 2024, Principal Associate Deputy Attorney General Marshall Miller provided an update on the Justice Department’s (DOJ) corporate criminal enforcement efforts during his keynote address at the Practicing Law...more
Saves Lives, Prevents Major Crimes, and Accelerates Voluntary Self - Disclosures The U.S. Department of Justice (“DoJ”) recently spotlighted its Whistleblower Awards Program and Voluntary Self Disclosure (“VSDs”)...more
Corporate Whistleblower Awards Pilot Program (“Pilot Program”), aimed at incentivizing whistleblowers to report potential criminal conduct. The announcement was anticipated, having been previewed in March 2024 by Deputy...more
The Securities & Exchange Commission, the Department of Health & Human Services, and other agencies have long had established bounty programs that reward successful tipsters. On August 1, 2024, the Department of Justice’s...more
Earlier this month, the U.S. Department of Justice (DOJ) announced its Corporate Whistleblower Awards Pilot Program (Program). The Program—which will last for three years—is designed to incentivize, through money awards,...more
Whistleblower awards from regulatory agencies seldom make news in corporate compliance circles anymore, but two recent items from the world of whistleblower awards do deserve compliance officers’ attention. They’re a reminder...more
Historically, successful white-collar prosecutions often turn on the government’s ability to identify “insiders” with firsthand knowledge of the alleged criminal scheme, who opt to cooperate with prosecutors in exchange for...more
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
In its never-ending war on corporate fraud, the Department of Justice (“DOJ”) has just commissioned a private army to fight as never before. On August 1, the DOJ launched a three-year program to provide financial rewards to...more
For years, Department of Justice officials have stressed how important chief compliance officers are as the first line of defense in fighting corporate crimes. While that’s true, compliance programs now have a competitor in...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
Department of Justice (DOJ) Deputy Attorney General Lisa Monaco announced that the DOJ is adopting a whistleblower incentive program today at the American Bar Association’s 39th National Institute on White Collar Crime. In...more
Just one day after Deputy Attorney General Lisa Monaco announced the U.S. Department of Justice’s (“DOJ’s” or “Department’s”) whistleblower pilot program on March 8, 2024, the DOJ’s Criminal Division highlighted its plans to...more
Fireside Chat with Attorney General Merrick Garland - A highlight of the conference was a fireside chat with Attorney General Merrick Garland. AG Garland first discussed the important lead the United States has with...more
On March 7, 2024, Deputy Attorney General (“DAG”) Lisa Monaco announced a new Department of Justice (“DOJ”) pilot program to pay whistleblower rewards (“the Program”) for individuals who report corporate misconduct. As the...more
Over this series, I have reviewed the messages communicated by the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) from three key Foreign Corrupt Practices Act (FCPA) enforcement actions regarding...more
In recent years, the Department of Justice (DOJ) has rolled out a significant and increasing number of carrots and sticks aimed at deterring and punishing white collar crime. Speaking at the American Bar Association White...more
The US Department of Justice (DOJ) continues to enhance its tougher-on-corporate-crime policy stance as first announced by Deputy Attorney General Lisa Monaco in 2021. In remarks on March 7 and March 8, DAG Monaco and Acting...more
As lawyers, corporate executives and federal law enforcement officials prepare to gather this week in San Francisco for the ABA’s 39th National Institute on White Collar Crime, we offer our takeaways from January’s Houston...more
Over the past 15 months, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have made clear, through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more
January saw continuing focus on Russia. First, the Commerce Department’s Bureau of Industry and Security (BIS) expanded export controls on certain goods for Russia and Belarus. Second, a U.S.-Israeli citizen was arrested for...more
We continue our exploration of the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. Today we go full geek in a look at the fine and penalty and most importantly what the fine and penalty communicate about what the...more
On November 28–30, 2023, the American Conference Institute’s 40th International Conference on the Foreign Corrupt Practices Act (“FCPA”), held in Washington, D.C., brought together prosecutors, regulators, corporate...more