News & Analysis as of

Voluntary Disclosure FCPA Corporate Enforcement Policy (CEP)

Morrison & Foerster LLP

DOJ Criminal Division Revises Its Corporate Enforcement Policy, Monitor Selection Policy, and Whistleblower Award Program

On May 12, 2025, the Criminal Division of the U.S. Department of Justice (DOJ) revised its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) and Corporate Whistleblower Awards Pilot Program (Whistleblower...more

Epstein Becker & Green

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

Epstein Becker & Green on

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

Mintz

Another Declination from DOJ’s Criminal Division Emphasizes the Continued Focus on Voluntary Self-Disclosure in 2024

Mintz on

Drawing on a carrot and stick approach, Department of Justice (“DOJ” or the “Department”) guidance in 2023 focused heavily on incentivizing companies to voluntarily self-disclose their misconduct. This guidance included the...more

Mayer Brown

US Department of Justice Criminal Division Announces New Pilot Program Encouraging Individual Voluntary Self-Disclosures

Mayer Brown on

On April 15, 2024 the Criminal Division of the US Department of Justice (“DOJ”) launched a pilot program to encourage voluntary self-disclosures by offering mandatory non-prosecution agreements (“NPAs”) to individuals who...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

Vinson & Elkins LLP

“Call Us Before We Call You”: SDNY Creates New Individual Self-Disclosure Program

Vinson & Elkins LLP on

On January 10, 2024, the United States Attorney’s Office for the Southern District of New York (“SDNY”) introduced the SDNY Whistleblower Pilot Program (“Pilot Program”), aimed at encouraging individuals to disclose...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2023 Developments and Predictions for 2024

WilmerHale on

Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more

Guidepost Solutions LLC

DOJ Maintains Interest in Bribery in Mexico and Latin America

Recent Department of Justice (“DOJ” or “Department”) activity on bribery in Mexico and Latin America sends a warning and provides a roadmap to companies doing business there.  By following the roadmap, companies may escape...more

J.S. Held

Building a Strong Compliance Program That Meets the Revised DOJ Corporate Enforcement Policy

J.S. Held on

A corporate compliance program can be thought of as a magnet that brings a company’s compliance efforts together. It is an operational program, not simply a code of expected ethical behavior. An effective compliance...more

Paul Hastings LLP

A Commitment to Transparency: Clarifying Key Enhancements to the U.S. Department of Justice’s Corporate Enforcement Guidance

Paul Hastings LLP on

Since September 2022, the U.S. Department of Justice (“DOJ” or “the Department”) has made a number of announcements signaling notable changes to its U.S. corporate enforcement policies. These changes include key revisions to...more

Burr & Forman

In Wake of DOJ’s Emphasis on Corporate Criminal Enforcement, Companies Should Listen Carefully to Whistleblower Complaints

Burr & Forman on

On February 22, 2023, the U.S. Department of Justice (DOJ) announced updated guidance on the Voluntary Self-Disclosure Policy (VSD Policy). The VSD Policy went into effect immediately in every U.S. Attorney’s Office across...more

The Volkov Law Group

Corsa Coal Earns Declination and Agreed to Disgorge $1.2 Million

The Volkov Law Group on

The Justice Department has been pushing its voluntary self-disclosure program and changes to its Corporate Enforcement Policy, in an attempt to increase FCPA enforcement cooperation.  The Golden Ring for every company facing...more

Polsinelli

Annual ABA White Collar Conference Brings Additional Updates to DOJ Corporate Enforcement Policy

Polsinelli on

Last week at the American Bar Association’s annual National Institute on White Collar Crime in Miami, Deputy Attorney General Lisa Monaco and Assistant Attorney General Kenneth A. Polite highlighted several new facets of the...more

Cadwalader, Wickersham & Taft LLP

US Attorneys’ Offices Issue New Voluntary Self-Disclosure Policy As Efforts to Incentivize More Self-Reporting Continue

On February 22, 2023, the United States Attorneys’ Offices (USAO) issued a new Voluntary Self-Disclosure (VSD) Policy, which is effective immediately. The policy follows the revisions announced last month to the Department of...more

Morrison & Foerster LLP

U.S. Department of Justice Announces New Voluntary Self-Disclosure Policy for all U.S. Attorney’s Offices

Key Takeaways- On February 22, 2023, the U.S. Department of Justice (DOJ) announced a new corporate voluntary self-disclosure (VSD) policy applicable to all 94 U.S. Attorney’s Offices across the United States and its...more

Epstein Becker & Green

To Disclose or Not to Disclose: DOJ Revises Its Policy on How Corporate Criminal Matters Are Handled in an Attempt to Further...

In response to a recent Department of Justice (DOJ) request that all DOJ components write voluntary self-disclosure policies and “clarify the benefits of promptly coming forward to self-report [as] a good business decision,”...more

Wilson Sonsini Goodrich & Rosati

In the Year of the Rabbit, the DOJ Dangles More Carrots to Incentivize Self-Disclosure and Cooperation

Whenever a company detects criminal misconduct, it is faced with the difficult decision of whether to self-disclose the misconduct to the federal government. In an attempt to help nudge companies towards cooperation, the U.S....more

Vinson & Elkins LLP

Carrots Take Root: DOJ Significantly Revamps Corporate Enforcement Policy to Increase Incentives for Companies to Cooperate

Vinson & Elkins LLP on

In an apparent response to a downturn in corporate cases and criticism that its harsh rhetoric was chilling corporate cooperation, the Department of Justice (“DOJ”) recently announced significant changes to its policy on...more

The Volkov Law Group

Justice Department Tweaks Corporate Enforcement Policy to Entice More Corporate Voluntary Disclosures

The Volkov Law Group on

The Department of Justice announced revisions to its Corporate Enforcement Policy (“CEP”) yet again in order to promote voluntary disclosures by Companies that discover potential wrongdoing.  DOJ’s latest action demonstrated...more

Hogan Lovells

DOJ sets forth new incentives for companies to self-disclose and cooperate

Hogan Lovells on

On January 17, 2023, the Department of Justice (DOJ) rolled out revisions to its Corporate Enforcement Policy (CEP) aimed at incentivizing companies to voluntarily self-disclose misconduct and to cooperate with government...more

Akin Gump Strauss Hauer & Feld LLP

DOJ Criminal Division Announces New Round of Revisions to Corporate Enforcement Policy

Key Points - On January 17, 2023, Assistant Attorney General Kenneth A. Polite, Jr. announced revisions to the DOJ Criminal Division’s corporate enforcement policy that offer new incentives to self-disclose corporate...more

Herbert Smith Freehills Kramer

Assistant Attorney General Kenneth A. Polite Jr. Announces Revisions to DOJ Criminal Division’s Corporate Enforcement Policy

Eager to enlist corporations as “allies in [its] fight against crime,” the Department of Justice (DOJ) announced on Tuesday, Jan. 17, 2023, expansions to the Criminal Division’s corporate enforcement policy, now the Criminal...more

Wiley Rein LLP

DOJ’s “Carrot” Approach to Corporate Enforcement Policy (But Read the Fine Print)

Wiley Rein LLP on

Last Tuesday, the Department of Justice (DOJ) announced the most recent modifications to its Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) in an effort to further encourage companies to...more

Paul Hastings LLP

Bigger Carrots, More Sticks? DOJ Revises Its Corporate Criminal Enforcement Policy

Paul Hastings LLP on

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

Morgan Lewis

DOJ Criminal Division’s Corporate Enforcement Policy: Is 2023 the Year of the Carrot?

Morgan Lewis on

The US Department of Justice (DOJ) continues to try to dispel lingering skepticism over the benefits of corporate disclosure and cooperation. In remarks delivered on January 17, Assistant Attorney General (AAG) Kenneth A....more

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