News & Analysis as of

Voluntary Disclosure Corruption Corporate Misconduct

Wiley Rein LLP

DOJ’s Approach to White Collar Enforcement: Target Those Who Harm U.S. Interests While Minimizing Collateral Damage

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The U.S. Department of Justice (DOJ) recently announced Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA). The June 9 memorandum from Deputy Attorney General Todd Blanche instructs...more

Carlton Fields

DOJ Policy Changes Have Made Internal Investigations More Important Than Ever

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Internal investigations have long been a valuable tool for companies and their executives to manage civil, regulatory, and criminal liability. By investigating potential corporate misconduct with the help of counsel, a...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for December 2024

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

Jones Day

Dutch Public Prosecution Office Publishes Rules on Self-Disclosure, Cooperation and Self-Investigation

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The Dutch Public Prosecution Office ("DPPO") has introduced a new policy (aanwijzing), effective 1 January 2025, outlining conditions and fine reductions for self-disclosure, cooperation and self-investigation in corporate...more

Holland & Hart LLP

Key Compliance Takeaways for Companies from the DOJ's New Corporate Whistleblower Program

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On August 1, 2024, the U.S. Department of Justice (“DOJ”) announced its new “Corporate Whistleblower Awards Pilot Program” (“DOJ Program”), a three-year initiative managed by DOJ’s Money Laundering and Asset Recovery Section....more

Mintz

DOJ Issues its Highly Anticipated Whistleblower Awards Pilot Program

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In March 2024, at the American Bar Association’s 39th National Institute on White Collar Crime, Deputy Attorney General (“DAG”) Lisa Monaco announced that the Department of Justice (“DOJ” or the “Department”) intended to...more

Baker Donelson

Update: DOJ Launches Corporate Whistleblower Awards Program

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In March, the Department of Justice (DOJ) announced that a pilot program to incentivize individualized reporting was in development, which we reviewed here. True to its word, the DOJ's "Corporate Whistleblower Awards Pilot...more

Robinson & Cole LLP

Legal Update: DOJ Issues Final Guidance on New Whistleblower Awards Pilot Program, Placing Premium on Prompt and Detailed...

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On August 1, 2024, the Department of Justice (DOJ) issued final guidance on its Corporate Whistleblower Awards Pilot Program (Program), offering financial incentives to qualifying individuals who report certain criminal...more

McDermott Will & Schulte

DOJ Unveils Details of Corporate Whistleblower Awards Pilot Program

On August 1, 2024, the US Department of Justice’s (DOJ’s) Principal Deputy Assistant Attorney General of the Criminal Division, Nicole Argentieri, unveiled the highly anticipated details of DOJ’s Corporate Whistleblower...more

Jones Day

DOJ Criminal Division Offers Non-Prosecution Agreements to Individuals Who Voluntarily Report Corporate Wrongdoing

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The Development: On April 15, 2024, the Department of Justice ("DOJ") Criminal Division announced a pilot program that will offer mandatory non-prosecution agreements ("NPAs") to individuals who provide original and...more

Epstein Becker & Green

The Department of Justice’s Criminal Division Launches a Pilot Program on Voluntary Self-Disclosures for Individuals

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Since October 2021, the Department of Justice (DOJ) has been implementing a variety of changes to its corporate criminal enforcement policies. These efforts all reflect DOJ’s focus on individual accountability, punishing...more

Cranfill Sumner LLP

The Department of Justice Unveils Groundbreaking Pilot Program: Incentivizing Whistleblowers with Immunity

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On April 15, 2024, the Department of Justice (“DOJ”) released an internal memo introducing a Pilot Program on Voluntary Disclosures intended to encourage individuals – from executives to lower-level employees – to report...more

The Volkov Law Group

Carrots and Sticks: DOJ’s Push to Incentivize Voluntary Disclosure of Corporate Misconduct (Part II of II)

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DOJ has been on a public relations campaign to push a simple message for corporations: if companies learn of misconduct, companies should disclose such misconduct to earn valuable benefits.  The quintessential question...more

Benesch

White Collar Quarterly Report | Q1 2024

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We are thrilled to introduce the inaugural issue of our quarterly White Collar newsletter, a dedicated resource from Benesch’s White Collar, Government Investigations & Regulatory Compliance Practice Group. Each issue...more

Fisher Phillips

Feds Encourage Companies to Come Clean on Criminal Conduct and Reward Whistleblowers for Reporting Wrongdoing: Key Takeaways for...

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Federal prosecutors are exploring new ways to encourage business leaders to invest in their corporate compliance programs. Indeed, a Department of Justice official recently announced several new programs incentivizing...more

Eversheds Sutherland (US) LLP

More carrots, more sticks - DOJ announces agency-wide whistleblower pilot program

The Department of Justice has announced yet another pilot program, adding to their “mix of carrots and sticks” designed “to promote responsible corporate citizenship.” The new whistleblower pilot program, which is still under...more

Thomas Fox - Compliance Evangelist

Argentieri at ABA White Collar Conference: Corporate Enforcement, Part 1

There were recently two significant speeches by Department of Justice (DOJ) officials at the American Bar Association National Institute on White Collar Crime. The first was by Deputy Attorney General Lisa Monaco. The second...more

Thomas Fox - Compliance Evangelist

DAG Monaco at ABA White Collar Conference: Self-Disclosure, Wanted Posters and AI

There were recently two significant speeches by Department of Justice (DOJ) officials at the American Bar Association National Institute on White Collar Crime. The first was by Deputy Attorney General Lisa Monaco. The second...more

Troutman Pepper Locke

SDNY Ramps Up Pressure on Companies to Voluntarily Disclose Wrongdoing

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On February 13, the U.S. Attorney’s Office (USAO) for the Southern District of New York (SDNY) announced a pilot program through which whistleblowers who voluntarily self-disclose criminal conduct relating to public or...more

Thomas Fox - Compliance Evangelist

Self-Disclosure is Now the Key

The Department of Justice (DOJ) has been making significant strides in emphasizing the importance of voluntary self-disclosure in corporate enforcement cases, particularly in the realm of the Foreign Corrupt Practices Act...more

Mintz

EnforceMintz — DOJ’s Efforts in 2023 to Incentivize Voluntary Self-Disclosure

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2023 was a very active one for Department of Justice (DOJ or the “Department”) guidance, and that guidance had one clear theme: DOJ wants companies to voluntarily self-disclose their misconduct. To incentivize...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

Troutman Pepper Locke

The Stick and the Carrot: DOJ Continues to Eye Corporate Crimes, While Encouraging Prompt Self-Disclosures of Misconduct...

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On October 4, Deputy Attorney General (DAG) Lisa Monaco announced the Department of Justice’s (DOJ) new Safe Harbor Policy for voluntary self-disclosures made in connection with mergers and acquisitions (M&A). This policy is...more

Robinson & Cole LLP

DOJ Announces Extension of Voluntary Self-Disclosure Guidance for Misconduct Discovered Through M&A Due Diligence

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On October 4, 2023, the U.S. Department of Justice (DOJ) announced a uniform approach for the resolution of voluntary self-disclosure (VSD) of misconduct discovered during M&A due diligence. The Mergers & Acquisitions Safe...more

Barnea Jaffa Lande & Co.

Cooperating May Credit Corporations with Leniency in Enforcement

Last September, US Deputy Attorney General Lisa Monaco issued a memorandum instructing the various departments in the Department of Justice to adopt a lenient enforcement policy toward corporations. The aim of this policy is...more

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