Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Encouraging and Managing Employee Self-Reporting
The Latest on Antitrust Compliance
Andy Dunbar and Nick Morgan on What the SEC Expects from Your Internal Investigation
Compliance Perspectives: The Antitrust Division’s Office of Decree Enforcement
FERC: A Discussion on its Mission, Market Manipulation Investigations, and Common Violations
Investment Management Roundtable Discussion – Regulatory and Enforcement Update
Podcast - Risk Management: Impact of Revised FCPA Policy on International Risk Management Programs
FCPA Compliance and Ethics Report-Episode 380, Laura Perkins on issues around self-disclosure
Nonpayment of Subcontractors: Can Subcontractors Get Any Help From the Government?
Episode 155-Mara Senn on FCPA Investigations and the Decision to Self-Disclose
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
Corporate Criminal Liability – Interview with Bridget Rohde, Member, Mintz Levin
A recent whistleblower suit could impact a company’s deferred prosecution agreement (“DPA”) potentially leading to further investigation by DOJ and additional penalties. A whistleblower suit was recently filed in the New...more
The Department of Justice’s (DOJ) recent announcement that it would decline to prosecute a self-reported criminal export control violation demonstrates the continuing importance of prompt, voluntary self-disclosure (VSD) and...more
The updated guidance puts a heavy emphasis on self-reporting and clarifies how corporates under investigation can earn cooperation credit from UK prosecutors....more
On 24 April 2025, the Serious Fraud Office (SFO) issued new guidance signalling a notable shift in its approach to corporate criminal enforcement. For the first time, the SFO has stated that if a company self-reports...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
Motivated by a “visceral reaction” to large-scale economic crime, Nick Ephgrave lays out vision for a bolder, more pragmatic, and more proactive agency. Whistleblowers, dawn raids, and cross-agency collaboration are all...more
The year 2023 ended with a bang in the cartel space, with a federal court of appeals upending what was long believed to be the scope of conduct that should be considered per se under the Sherman Act. The new year, 2024,...more
Introduction - A perennial message from the Securities and Exchange Commission (SEC) Division of Enforcement is to extol the benefits of cooperation with enforcement investigations. The link between cooperation and a...more
On February 22, 2023, the U.S. Department of Justice (DOJ) announced a new nation-wide policy to incentivize companies to self-report criminal activity. Among the cited benefits of self-reporting are discounts on fines and...more
Earlier this month, the Department of Justice (DOJ) announced a $5.2 million civil settlement agreement to resolve small business set-aside fraud allegations against an aerospace contractor. While the $5+ million...more
The DOJ Antitrust Division recently announced new requirements for DOJ's Leniency Program, which allows the first individual or company to self-report its involvement in an antitrust conspiracy to avoid prosecution and lessen...more
On April 4, 2022, the U.S. Department of Justice Antitrust Division (the “Division”) announced noteworthy updates to its Corporate Leniency Program as well as its frequently asked questions (“FAQs”) that explain the Program,...more
On April 4, 2022, the U.S. Department of Justice’s Antitrust Division announced significant changes to its flagship leniency program. Largely unchanged since 1993, the leniency program allows any member of a cartel, whether...more
Our one-day Regional Compliance Conferences provide attendees with a forum to interact with local compliance professionals, share information about your compliance successes and challenges, and create educational...more
Morgan Lewis’s 15th annual 2020 Year in Review and a Look Forward provides a comprehensive overview and analysis of key 2020 US Securities and Exchange Commission (SEC) enforcement and examination developments, notable...more
The Serious Fraud Office (“SFO”) has recently updated its Operational Handbook to include a chapter on DPAs (the "Updated Handbook"). For companies under investigation, the question of whether or not to cooperate with the...more
The Antitrust Criminal Penalty Enhancement and Reform Act (ACPERA), which provides additional benefits to the Leniency Program within the Department of Justice (DOJ), was reauthorized by President Trump on October 1, 2020....more
In a significant move toward more transparency, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) released new guidance (the “Guidance”) on August 18, 2020, setting forth its enforcement approach and...more
- A tone-at-the-top business culture with CEO leadership is a critical component of effective anti-corruption and anti-bribery policy implementation. - CEO leadership helps set an example for lower management and company...more
The Situation: The U.S. Department of Justice ("DOJ") has issued guidance revising its 2016 voluntary disclosure policy to provide companies stronger incentives to voluntarily self-report apparent potentially willful trade...more
In a development that could significantly affect how companies deal with possible export control and sanctions violations, the Department of Justice (“DOJ”) recently revised its policy regarding voluntary disclosure of trade...more
On March 8, 2019, the Department of Justice (“DOJ”) released a revised version of its FCPA Corporate Enforcement Policy (the “Policy”), which provides enforcement and practice guidance to DOJ prosecutors and was formally...more
After a year-long pilot, the Department of Labor’s employer-self-audit initiative is apparently here to stay. Which begs the question: should you participate? Let’s look at the most common questions and provide some answers....more
Quick Hit: OFCCP’s Directive 2019-04 reveals the development a Voluntary Enterprise-Wide Review Program (“VERP”). Once established, contractors will be able to voluntarily participate in the program, submitting themselves to...more
Under the second year of the Trump Administration, the biggest story was the increase of corporate declinations one year after the DOJ adopted a permanent FCPA policy incentivizing self-disclosure, cooperation, and...more