Understanding the DOJ's Recent Corporate Enforcement Policy Changes
Episode 369 -- Stepping Into the Enforcement Spotlight -- Customs and Border Patrol and Import Enforcement
Understanding the Latest DOJ Changes to Corporate Prosecutions
The Justice Insiders Podcast: Self-Disclosure, Cooperation, and the Hazards of Knowing Too Little
5 Key Takeaways | 2024 Emerging Trends: Delaware Unclaimed Property VDA and Multistate Audits
The Presumption of Innocence Podcast: Episode 44 - A Recipe for Litigation: The Simmering Conflict Surrounding ERC Claims
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
FCPA Survival Guide: Step 1 - Self-Disclosure
Episode 316 -- DOJ Announces New Whistleblower Policy
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
The Presumption of Innocence Podcast: Episode 28 - Under the Microscope: Examining the Future of the ERC
Episode 289 -- Justice, Commerce and Treasury Issue Joint Notice on Voluntary Disclosure
What DAG Lisa Monaco's Speech Means for Compliance Programs
Torres Talks Trade Podcast- Episode 13- When Government Agencies Come Knocking
Torres Talks Trade Episode 11 on Sanctions and Export Enforcement Cases by DOJ
The Justice Insiders Podcast: The DOJ Wants You! - Part II: Voluntary Disclosures
Williams Mullen's Comeback Plan: Part I – State & Local Tax (SALT) Compliance During COVID-19: What to Do When You’re Behind
Anti-corruption & international risk developments
Podcast - Risk Management: Impact of Revised FCPA Policy on International Risk Management Programs
Podcast - Risk Management: Revised FCPA Corporate Enforcement Policy
In a significant policy shift, the IRS has revised Form 14457, Voluntary Disclosure Practice Preclearance Request and Application, the cornerstone of its Voluntary Disclosure Practice (VDP), by removing the controversial...more
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
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
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
Is it too late to correct past FBARs and file amended returns with the IRS? The net is closing in on U.S. taxpayers with unreported or under-reported domestic and offshore income and assets. The IRS has increased audits in...more
Saves Lives, Prevents Major Crimes, and Accelerates Voluntary Self - Disclosures The U.S. Department of Justice (“DoJ”) recently spotlighted its Whistleblower Awards Program and Voluntary Self Disclosure (“VSDs”)...more
On October 10, 2024, Attorney General Merrick Garland announced that TD Bank agreed to pay over $1.8 billion in penalties to resolve the U.S. Department of Justice’s (DOJ) investigation into money laundering and Bank Secrecy...more
What are the IRS revisions to the Voluntary Disclosure Program for 2024? The foundation of the current IRS Voluntary Disclosure Program (VDP) goes as far back as 2009 when the agency worked to provide U.S. taxpayers with a...more
Who may be interested: Registered Investment Advisers, Registered Investment Companies, Compliance Staff - Quick Take: The SEC recently announced a number of additional enforcement actions relating to recordkeeping...more
New export controls, new section 301 duties, new OFAC requirements, new de minimis rule, new DOJ corporate compliance guidance, new international guidance on Russian sanctions. September had it all....more
On Monday, September 23, DOJ’s Criminal Division announced updates to its guidance for evaluating corporate compliance programs (“ECCP”). Principal Deputy Assistant Attorney General Nicole Argentieri also delivered remarks...more
As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more
August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more
As the year gets underway, the Securities and Exchange Commission (SEC or Commission) is continuing its ongoing enforcement efforts to target anti-whistleblower practices by pursuing a broader range of entities and...more
The U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published their second Tri-Seal...more
Voluntary self-disclosure is a valuable remediation measure for companies who identify their own potential violations of U.S. sanctions, export controls, and other national security laws....more
During speeches earlier this month, Deputy Attorney General Lisa Monaco and Assistant Attorney General for the Criminal Division Kenneth A. Polite, Jr. announced significant changes to the way DOJ evaluates corporate...more
On September 15, 2022, the Department of Justice (DOJ) released a long-anticipated memo announcing changes to its corporate criminal enforcement policies (Memo). The Memo contains helpful guidance for employers, outlining...more
The "Report of Foreign Bank and Financial Accounts" (FBAR) penalty has been the subject of much litigation. This Holland & Knight alert focuses on the non-willfulness element of 31 U.S.C. § 5321(a)(5)(B). Both the U.S. Court...more
Report on Supply Chain Compliance 3, no. 2 (January 23, 2020) - The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), the primary U.S. government agency that administers U.S. economic sanctions, was busy...more
On May 6, 2019, the Justice Department issued new policies establishing how defendants in False Claims Act (FCA) matters can earn credit for voluntary self-disclosure, cooperation, and remediation, possibly reducing what...more