News & Analysis as of

Self-Reporting Department of Justice (DOJ) Deferred Prosecution Agreements

Womble Bond Dickinson

Can a Whistleblower Derail a Deferred Prosecution Agreement?

Womble Bond Dickinson on

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

Snell & Wilmer

DOJ Updated Corporate Criminal Enforcement Policies

Snell & Wilmer on

In a highly anticipated speech, Deputy Attorney General Lisa O. Monaco delivered remarks outlining updates to the U.S. Department of Justice (“DOJ”) perspective on the Corporate Crime Enforcement policy. These updates are the...more

Vinson & Elkins LLP

DOJ Chooses Sticks Over Carrots: Three Reasons Why Changes to DOJ’s Corporate Enforcement Policy May Chill Cooperation by...

Vinson & Elkins LLP on

In announcing recent changes to its corporate criminal enforcement policies, the Department of Justice (“DOJ” or the “Department”) continued its forceful “tough on crime” initiatives to deter wrongdoing....more

Moore & Van Allen PLLC

Latest DOJ Spoofing Settlement

Moore & Van Allen PLLC on

On November 6, 2019, the Fraud Section of the Department of Justice with the Office of the U.S. Attorney for the Southern District of Texas, and the CFTC, announced settlements of their spoofing and market manipulation...more

Jones Day

Antitrust Alert: New DOJ Criminal Enforcement Policy Boosts Value of Antitrust Compliance Programs

Jones Day on

The U.S. Department of Justice Antitrust Division ("DOJ") recently announced significant revisions to its criminal enforcement policies regarding the value it places on a company's pre-existing antitrust compliance program....more

Bracewell LLP

DOJ Changes Criminal Policy to Recognize Antitrust Compliance Programs

Bracewell LLP on

In a major policy shift, the Antitrust Division of the Department of Justice recently announced that it will now credit companies for effective corporate antitrust compliance programs in making charging decisions and penalty...more

Thomas Fox - Compliance Evangelist

TechnipFMC FCPA Enforcement Action-Lessons Learned

We continue our exploration of the TechnipFMC Foreign Corrupt Practices Act (FCPA) enforcement action by considering the actions taken by the company (or both separately before their merger) in response to their FCPA...more

Vedder Price

DOJ Criminal Division Announces Major Change in Corporate Enforcement Policy

Vedder Price on

On March 1, 2018, the Criminal Division of the U.S. Department of Justice (“DOJ”) announced that it has expanded the scope of cases in which it will consider issuing a formal declination of criminal charges for a company that...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Sapin II Act: New Perspectives on Cross-Border Investigations

On November 30, 2017, the Institut des Hautes Etudes sur la Justice (IHEJ) and Skadden hosted a roundtable at the Cercle de l’Union Interalliée in Paris to discuss new perspectives on the Sapin II Act and cross-border...more

BakerHostetler

DOJ Publishes Guidance Encouraging Voluntary Self-Disclosures, Full Cooperation and Timely and Appropriate Remediation

BakerHostetler on

On Oct. 2, 2016, the U.S. Department of Justice (DOJ), National Security Division (NSD) published Guidance setting forth its policy of encouraging business organizations to voluntarily self-disclose criminal violations of...more

Troutman Pepper Locke

The Spring Meeting Confronts the Yates Memo: Execs in the Front Lines of Corporate Criminal Responsibility; Presentation of the...

Troutman Pepper Locke on

The Business Law Section’s Director and Officer Liability Committee conducted a program at the Section’s Spring Meeting in Montréal. The program focused on the recent Yates memorandum of the U.S. Department of Justice (DOJ),...more

Thomas Fox - Compliance Evangelist

The UK Bribery Act: SFO Procedures and DPA Process

A couple of recent articles about the UK Serious Fraud Office (SFO) caught my attention. One was on thebriberyact.com, entitled “Opinion: DPA’s must show greater benefits. We discuss the Criteria & Process for a DPA set out...more

Williams Mullen

USDOJ Beefs Up FCPA Efforts

Williams Mullen on

In April, the Fraud Section of the United States Department of Justice announced several measures designed to enhance its effort to discover and prosecute violations of the Foreign Corrupt Practices Act (FCPA). See, 15 U.S.C....more

Dorsey & Whitney LLP

Dorsey Anti-Corruption Digest - April 2016

Dorsey & Whitney LLP on

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more

WilmerHale

A transatlantic consideration of recent developments in corporate self-reporting

WilmerHale on

More carrot, less stick? On 5 April 2016, the Fraud Section of the US Department of Justice’s (DOJ) Criminal Division issued an Enforcement Plan and Guidance (the DOJ Guidance), setting out the steps that it is taking to...more

BakerHostetler

Foreign Corrupt Practices Act 2015 Year-End Update

BakerHostetler on

Both the United States Department of Justice (DOJ) and the United States Securities and Exchange Commission (SEC) have continued their focus on anticorruption enforcement in 2015. Although there was a decline in enforcement...more

Dorsey & Whitney LLP

Takeaways From UK's 1st Deferred Prosecution Agreement

Dorsey & Whitney LLP on

In a judgment published on Nov. 30, Lord Justice Brian Leveson approved the first deferred prosecution agreement in the U.K., which was negotiated between the Serious Fraud Office and ICBC Standard Bank PLC. Lord Justice...more

NAVEX

The Future of U.K. Enforcement of Financial Crimes: Four Clues for 2015

NAVEX on

The legal and compliance landscape is changing quickly—it’s up to organisations that do business in the U.K. to strengthen their compliance programmes to meet these new challenges. In this whitepaper, Andrew Foose, vice...more

Thomas Fox - Compliance Evangelist

Alstom Joins Santa’s Naughty List – In a Very Big Way

The North Pole for Foreign Corrupt Practices Act (FCPA) enforcement action announcements seems to have temporarily moved south for the month of December. Last week there was the final announcement of the long-standing Avon...more

Stinson LLP

Dallas Airmotive, Inc.'s FCPA Matter Offers Practical Insights and Continuing Lessons

Stinson LLP on

On December 10, 2014, DOJ filed a criminal Information alleging (i) conspiracy and (ii) violation of the bribery provisions of the FCPA against Dallas Airmotive, Inc., an aircraft engine maintenance, repair and overhaul...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions

In this episode, I review the corporate FCPA enforcement actions of 2013. ...more

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