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Voluntary Disclosure Criminal Prosecution Corporate Misconduct

Troutman Pepper Locke

DOJ’s Revised Self-Disclosure Policy May Offer Companies More Certainty

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Last month, the DOJ Criminal Division (Division) revised its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), introducing several potentially significant changes intended to further incentivize companies to...more

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

Morrison & Foerster LLP

DOJ Issues First-Ever Declination Under Corporate Disclosure M&A Policy

On June 16, 2025, the Department of Justice (DOJ) National Security Division (NSD) announced that it declined to charge private equity firm White Deer Management LLC (“White Deer”) and its affiliates after the company...more

DLA Piper

Private Equity Acquirer Avoids “Unicat-astrophe” Following Voluntary Disclosures to the DOJ

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The US Department of Justice (DOJ) announced that it has formally declined to prosecute private equity firm White Deer Management LLC (White Deer) and certain of its affiliates in connection with criminal violations of US...more

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

McGlinchey Stafford

DOJ Overhauls Corporate Enforcement, Disclosure Policy, Offering Clearer Path to Leniency

McGlinchey Stafford on

The decision for a company to self-disclose potential criminal misconduct to the U.S. Department of Justice (DOJ) is always complex. This is particularly true during periods of administration transitions when DOJ policies and...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

Whiteford

Client Alert: Department of Justice’s New White Collar Crime Focus

Whiteford on

The Department of Justice’s Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime memorandum released on May 12, 2025, signals a shift in DOJ corporate criminal enforcement. The memorandum signals a shift...more

Wilson Sonsini Goodrich & Rosati

DOJ Streamlines Voluntary Self-Disclosure Policy for More Favorable Corporate Criminal Resolutions

When a company detects potential criminal misconduct, it must decide whether to self-disclose the misconduct to the U.S. Department of Justice (DOJ). This decision—while always complicated—is even more difficult during...more

Cohen Seglias Pallas Greenhall & Furman PC

DOJ Increases Incentives to Self-Disclose with Revised Corporate Enforcement Policy

Earlier this month, the Department of Justice (DOJ) announced revisions to the Corporate Enforcement and Self Disclosure Policy (CEP). Under the new policy, announced by DOJ Criminal Division Head Matthew Galeotti, companies...more

BakerHostetler

DOJ Criminal Division Announces Leniency and Potential Declination for Companies That Self-Disclose

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Earlier this month, the DOJ’s Criminal Division Head, Matthew R. Galeotti, spoke at the Securities Industry and Financial Markets Association’s (SIFMA) Anti-Money Laundering and Financial Crimes Conference in Washington,...more

Pillsbury Winthrop Shaw Pittman LLP

DOJ Announces Shift in Approach to Prosecuting Corporate Crime

The Criminal Division’s revisions to white-collar enforcement policies seek a new balance between uncovering corporate crime and unencumbering American businesses....more

Katten Muchin Rosenman LLP

Think Compliance Got Easier? Think Again—DOJ’s New Era in White-Collar Enforcement (Part 2)

As discussed in our May 15th post, Matthew R. Galeotti, the Head of the Department of Justice’s (“Department”) Criminal Division, issued a memorandum on May 12th that highlights the core tenets of the Department’s enforcement...more

ArentFox Schiff

DOJ Announces Revisions to Corporate Enforcement and Voluntary Disclosure Policy

ArentFox Schiff on

The US Department of Justice (DOJ) revised its Criminal Division Corporate Enforcement and Voluntary Disclosure Policy (CEP), outlining the benefits a company may earn by voluntarily self-disclosing misconduct, as well as the...more

Paul Hastings LLP

Criminal Division White Collar Enforcement Plan: Turning the Page, Not Writing a New Book

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On May 12, the Head of the U.S. Department of Justice (DOJ) Criminal Division, Matthew Galeotti, delivered remarks at the Securities Industry and Financial Markets Association’s Anti-Money Laundering and Financial Crimes...more

BakerHostetler

The DOJ Announces Administration’s Revised Corporate Enforcement Strategy

BakerHostetler on

On May 12, 2025, Matthew Galeotti, Head of the Department of Justice’s (DOJ) Criminal Division, unveiled a comprehensive white collar enforcement strategy titled “Focus, Fairness, and Efficiency in the Fight Against...more

Katten Muchin Rosenman LLP

Increased Clarity for White-Collar Clients: The Department of Justice Unveils its Revised Corporate Self-Disclosure Policy

What should U.S. businesses take from the Department of Justice’s (“DOJ”) revisions to its Corporate Enforcement and Voluntary Self-Disclosure Policy (“CEP”)? While DOJ has long promoted self-disclosure of wrongdoing as a...more

Foley & Lardner LLP

DOJ Criminal Division Updates (Part 3): New Reasons for Companies to Self-Disclose Criminal Conduct

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Share on Twitter Print Share by Email Share Back to top On May 12, 2025, the U.S. Department of Justice (DOJ) announced revisions to its Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP). (See...more

Womble Bond Dickinson

DOJ Announces Key Corporate Enforcement Changes & White-Collar Priorities

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DOJ recently announced white-collar crime enforcement priorities and significant changes to its corporate enforcement policies (here and here). “[O]verbroad and unchecked corporate and white-collar enforcement burdens U.S....more

Sheppard Mullin Richter & Hampton LLP

DOJ’s Updated Enforcement Policy: A Game-Changer for Corporate America?

On May 12, 2025, the U.S. Department of Justice (DOJ) announced a major overhaul of its corporate enforcement policy, aiming to incentivize companies to voluntarily self-disclose misconduct. Titled “Focus, Fairness, and...more

Goodwin

Trump 2.0’s DOJ: White-Collar Enforcement is Alive and Well

Goodwin on

Citing the need to strike a balance between “overbroad and unchecked corporate and white-collar enforcement [that] burdens U.S. businesses and harms U.S. interests” and “[u]nchecked fraud in U.S. markets and government...more

Faegre Drinker Biddle & Reath LLP

DOJ National Security Division Issues Second Declination Since Issuance of Revised Corporate Enforcement Policy

On April 30, 2025, the National Security Division (NSD) of the Department of Justice (DOJ) announced the declination of prosecution against the Universities Space Research Association (USRA), a federal government contractor,...more

Health Care Compliance Association (HCCA)

Private-pay “crime stoppers”: Digesting the Corporate Whistleblower Awards Pilot Program

The U.S. Department of Justice’s (DOJ) Criminal Division launched its Corporate Whistleblower Awards Pilot Program (“Criminal Whistleblower Program”) in August of 2024 to encourage tips for various types of fraud, including...more

The Volkov Law Group

DOJ’s Balancing Act — Incentives to Cooperate and Deterrence (Part III of III)

The Volkov Law Group on

While DOJ did not have an overwhelming FCPA enforcement year, DOJ has devoted significant energy to tweaking its enforcement and compliance policies.  These measures were believed to coincide with a number of significant...more

The Volkov Law Group

The FCPA Year in Review — More of the Same with Some Twists (Part I of III)

The Volkov Law Group on

With the end of the Biden Administration, it is hard to identify a consistent theme relating to FCPA enforcement.  On the one hand, the Biden Administration talked a big game, elevating the anti-corruption fight as a national...more

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