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
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
On May 12, 2025, Matthew Galeotti, the Head of the Criminal Division at the Department of Justice ("DOJ") issued a new white collar enforcement plan (“Enforcement Plan”) titled “Focus, Fairness, and Efficiency in the Fight...more
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
There was a flurry of DOJ whistleblower program activity over the last two weeks as the U.S. Attorneys’ Offices for the Eastern District of New York (EDNY Program), District of New Jersey (DNJ Program), Southern District of...more
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
Last month, the U.S. Department of Justice (DOJ) announced that it would not charge MilliporeSigma, a life sciences company, even though one of its employees falsified export documents. The DOJ declined to prosecute...more
Key Points - On May 21, 2024, the DOJ announced its first ever declination under the NSD’s updated Enforcement Policy, declining to prosecute Sigma-Aldrich Inc., d/b/a MilliporeSigma (a subsidiary of Merck KGaA, Darmstadt,...more
The white collar world had an active year, with the last 12 months yielding further incentives from the US Department of Justice (DOJ) to encourage voluntary disclosures as well as key rulings from the US Supreme Court that...more
In recent remarks, Principal Associate Deputy Attorney General (PADAG) Marshall Miller of the Department of Justice (DOJ) revealed that Deputy Attorney General Lisa Monaco will soon announce new voluntary self-disclosure...more
At the Global Investigations Review Annual Meeting in New York on September 21, 2023, Principal Associate Deputy Attorney General Marshall Miller (“Miller”) delivered remarks that provide an invaluable glimpse into the...more
Summary - Top U.S. Department of Justice officials announced the DOJ’s first-ever pilot program on corporate compensation incentives and clawbacks, as well as new policies on preservation of corporate communications, at...more
Assistant Attorney General Kenneth A. Polite, Jr. Announces Changes to Department of Justice Criminal Division’s Corporate Enforcement Policy - On January 17, 2023, Assistant Attorney General for the Criminal Division...more
The Department of Justice (DOJ) has been touting revisions to its corporate criminal enforcement policies and signaling increased action for nearly a year. Yesterday, Deputy Attorney General Lisa O. Monaco formally announced...more
This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more
The Situation: The U.S. Department of Justice ("DOJ") has issued guidance revising its 2016 voluntary disclosure policy to provide companies stronger incentives to voluntarily self-report apparent potentially willful trade...more
The Department of Justice recently announced updates to its Foreign Corrupt Practices Act Corporate Enforcement Policy. While the changes were relatively minor, the modifications underscored important principles surrounding...more
The Department of Justice tweaked its FCPA Corporate Enforcement Policy to further incentivize corporations to make voluntary disclosures. These small changes essentially acknowledge that companies in a very early stage of an...more
Over the last 10 years, 143 companies have paid a combined $10.9 billion to resolve Foreign Corrupt Practices Act cases. That staggering price tag shows the U.S. Department of Justice’s willingness to go after alleged...more
Deputy Attorney General Rod Rosenstein’s Nov. 29 announcement that the Department of Justice FCPA “Pilot Program” will be permanently expanded is good news for companies that repeatedly faced the dilemma of whether or not to...more
On November 29, 2017, Deputy Attorney General Rod Rosenstein announced that the U.S. Department of Justice (DOJ) was issuing a new enforcement policy covering its enforcement of the Foreign Corrupt Practices Act (FCPA). The...more
Last week the Department of Justice (DOJ) issued its second Declination under the Sessions regime. Short with brevity, the matter nonetheless has some significant points for the compliance practitioner to help move their...more
Yesterday I began an exploration of the General Cable Corporation (General Cable) Foreign Corrupt Practices Act (FCPA) enforcement action. It was settled with the DOJ via a Non-Prosecution Agreement (NPA) and the SEC via a...more
In a speech last week, Criminal Division Assistant Attorney General Leslie Caldwell touted the success of the FCPA Pilot Program. AAG Caldwell outlined the success of the FCPA enforcement program, listing many of the...more
The guidance issued by the DOJ in connection with the Pilot Program and recent declinations state that disclosure, remediation and cooperation are essential to any favorable resolution with the government. Six months...more
DOJ’s FCPA Pilot Program was panned when it was announced in April 2016. Critics contended that the incentive for voluntary disclosure of FCPA violations to DOJ was inadequate....more