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Self-Disclosure Requirements White Collar Crimes Corporate Governance

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

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

DLA Piper

How Argentina Reached a Turning Point for Corporate Accountability and Compliance in 2024

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In 2024, Argentina experienced a pivotal moment in corporate law enforcement with the first significant application of its Corporate Criminal Liability Law No. 27,401, enacted in 2018. This law holds private entities...more

Bradley Arant Boult Cummings LLP

250 Whistleblower Tips: DOJ Official Discusses New Programs with Incentives for Dropping a Dime on Corporate Crime

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

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

Polsinelli

"Please Pay No Attention to the Microphone:” DOJ Announces New Program Offering Protections to Criminal Whistleblowers

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On April 15, 2024, the Criminal Division of the U.S. Department of Justice (“DOJ”) released new guidance relating to a Pilot Program on Voluntary Self-Disclosures for Individuals, promising to offer protection from criminal...more

Perkins Coie

DOJ Pilot Program Changes the Calculus on Corporate Self-Disclosure

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The Criminal Division of the U.S. Department of Justice (DOJ) announced a Pilot Program on Voluntary Self-Disclosures for Individuals (Pilot Program) on April 15, 2024. Under the new policy, individuals who were involved in...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Pilot Program Promises Non-Prosecution Agreements to Individuals Reporting Fraud, Bribery and Other Corporate Crimes

On April 15, 2024, the Department of Justice’s (DOJ’s) Criminal Division unveiled a new Pilot Program on Voluntary Self-Disclosures for Individuals that offers non-prosecution agreements (NPAs) to individuals who voluntarily...more

Bradley Arant Boult Cummings LLP

DOJ Takes the Next Step in Its Effort to Increase Voluntary Self-Disclosures By Incentivizing Those Complicit in Wrongdoing

On April 15, the U.S. Department of Justice released The Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals (the “Pilot”) designed to encourage individuals to report certain types of criminal...more

Bradley Arant Boult Cummings LLP

“Take Me to the Pilot” – DOJ Announces Plan to Entice Self-Disclosures of Government Contract Fraud

On April 15, the U.S. Department of Justice released The Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals (the Pilot) designed to encourage individuals to report certain types of criminal...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

J.S. Held

Key Steps for Ensuring Regulatory Compliance in M&A: New Voluntary Safe Harbor Policy Updates

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In the dynamic realm of mergers and acquisitions, staying abreast of regulatory changes is paramount. The Department of Justice’s (DOJ) recent introduction of the Safe Harbor Policy for Voluntary M&A Self-Disclosures...more

McDermott Will & Emery

DOJ Unveils Voluntary Self-Disclosure Safe Harbor for M&A Deals

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On October 4, 2023, during remarks before the Society of Corporate Compliance and Ethics, Deputy Attorney General (AG) Lisa Monaco unveiled a new US Department of Justice (DOJ)-wide safe harbor policy for voluntary...more

Moore & Van Allen PLLC

DOJ Continues Efforts to Encourage Voluntary Corporate Self-Disclosure with New Safe Harbor Policy

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On October 4, 2023, Deputy Attorney General Lisa Monaco announced the next (but not final) chapter of the U.S. Department of Justice’s concerted attempt to promote voluntary corporate self-disclosure of misconduct with a new...more

A&O Shearman

U.S Department of Justice's new M&A safe harbor: what is it, what does it mean for M&A, and why now?

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On October 5, 2023, Deputy Attorney General, Lisa Monaco, announced a new safe harbor policy for voluntary self-disclosures made in the mergers and acquisitions context. The safe harbor policy will apply Department-wide and...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Previews M&A-Focused Guidance on Voluntary Self-Disclosure of Corporate Misconduct

In recent remarks, Principal Associate Deputy Attorney General (PADAG) Marshall Miller of the Department of Justice (DOJ) revealed that Deputy Attorney General Lisa Monaco will soon announce new voluntary self-disclosure...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investigations for Self-Disclosure Should Be Independent of DOJ To Avoid Fifth Amendment Issues

The Department of Justice (DOJ) has long encouraged companies to disclose to the DOJ potential violations of federal law, investigate themselves and report their findings in detail. The DOJ often depends on those self-reports...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

Jenner & Block

Client Alert: DOJ Expands the Reach of Its Policies on Self-Disclosure of Corporate Misconduct

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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

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

Fox Rothschild LLP

DOJ Formalizes Framework for Corporate Cooperation Credit

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The Department of Justice (DOJ) announced a new voluntary self-disclosure policy February 22, 2023, that sets uniform criteria for how and when prosecutors should reward corporate cooperation in criminal investigations. The...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

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

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