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Voluntary Disclosure FCPA Corporate Enforcement Policy (CEP) Corporate Governance

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

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

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

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