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Secretariat

Navigating New Rules of the Road: How Companies Can Adapt to Revised DOJ Guidance on Criminal Prosecutions

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Since the election in November 2024, there have been many changes to DOJ’s enforcement policies. Earlier this year, now-Acting Assistant Attorney General of the Criminal Division, Matthew R. Galeotti, announced at the...more

Troutman Pepper Locke

Making Compliance Your New Year's Resolution

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As we begin a new year, it is the perfect time for companies subject to any government agreement to renew their focus on compliance. These binding resolutions require ongoing diligence to avoid civil and potentially criminal...more

Akerman LLP

Enactment of the Foreign Extortion Prevention Act Expands the U.S. Department of Justice’s Ability to Prosecute International...

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The breadth of the recently enacted FEPA presents pitfalls for U.S. companies dealing with foreign governments and state-owned entities requiring significant caution and effective compliance controls....more

The Volkov Law Group

U.S. Sentencing Commission Report: Corporate Prosecutions Decline and Ethics and Compliance Programs Increase

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The proper balance in corporate prosecutions remains a tricky issue.  On the one hand, many argue that large fines and penalties against corporations are needed to deter criminal conduct, while others contend that...more

Morgan Lewis

DOJ Updates Corporate Compliance Evaluation Guidance: New Refinements Stress that Programs Need to be 'Empowered to Function...

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The US Department of Justice’s (DOJ’s) Criminal Division published an update on June 1 to its Evaluation of Corporate Compliance Programs guidance, which is used by its prosecutors to assess the adequacy and effectiveness of...more

The Volkov Law Group

Airbus Systemic Bribery and Export Violations: Understanding How a Company’s Compliance Program and Culture Failed (Part IV of IV)

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When reviewing a major enforcement case, I always ask two basic questions: What was the role of Board and senior management in the failure, and how did they fail to exercise proper oversight and ensure compliance?...more

Foodman CPAs & Advisors

Instituciones Financieras y el FCPA

La Ley de Prácticas Corruptas en el Extranjero (“Foreign Corrupt Practices Act – FCPA”) prohíbe el pago de sobornos a funcionarios extranjeros para ayudar a obtener o retener negocios.  Exige que las empresas cuyos valores se...more

Foodman CPAs & Advisors

Financial Institutions and the FCPA

The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business.  It requires companies whose securities are listed in the US to maintain books and...more

The Volkov Law Group

2019 FCPA Enforcement Highlights (Part II of III)

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In a record year, there are bound to be numerous interesting enforcement actions and principles.  I picked out a few to highlight....more

The Volkov Law Group

FCPA 2019: A Record Year in Enforcement and Compliance (Part I of III)

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Happy New Year!! In the FCPA arena, 2019 was a record year – in enforcement and compliance. Many continuing trends are becoming more than trends – meaning they are turning into established practices....more

Troutman Pepper Locke

New DOJ Policy on Corporate Antitrust Compliance Programs Provides Guidance for In-House Counsel and Compliance Officers

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On July 11, the U.S. Department of Justice rolled out a new policy to encourage stronger corporate antitrust compliance efforts. Announced by DOJ Antitrust Division head Makan Delrahim in remarks at the New York University...more

Orrick - Antitrust Watch

DOJ Changes Course and Announces That It Will Favorably Consider “Robust” Antitrust Compliance Programs at Both the Charging and...

Benjamin Franklin once observed that “an ounce of prevention is worth a pound of cure.” In the antitrust context, this means that most, if not all, companies will want as a matter of course to adopt and maintain an antitrust...more

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