News & Analysis as of

White Collar Crimes Compliance Criminal Investigations

Vinson & Elkins LLP

Small Gains Yield Big Pain: How a $2,400 Profit Triggered an SEC, FBI, and FINRA Cavalry

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On July 11, 2025, the Securities and Exchange Commission (“SEC” or the “Commission”) announced that it had settled an enforcement action against two individuals who were alleged to have engaged in insider trading. The SEC’s...more

Fenwick & West LLP

DOJ Unpauses FCPA Enforcement with New Limits

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On February 10, 2025, the president signed an executive order that paused investigation and enforcement of the FCPA for a period of 180 days, required the DOJ to review any existing FCPA investigation or prosecution, and to...more

Womble Bond Dickinson

New FCPA Guidance By DOJ

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The Department of Justice ("DOJ") recently announced new guidelines for investigations and enforcement of the Foreign Corrupt Practices Act (FCPA). ...more

The Volkov Law Group

McKinsey Company Pays $122 Million to Resolve FCPA Violations in South Africa (Part I of III)

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On December 5, 2024, DOJ announced a settlement with McKinsey and Company for $122 million for bribes paid to South African government officials to secure valuable consulting contracts....more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 47 - Fireside Chat With Bill Baroni and Jesse Eisinger

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Recorded at our 2024 White-Collar Symposium held in Philadelphia last month, this special episode dives into the landscape of white-collar criminal prosecution from the perspectives of Bill Baroni and Jesse Eisinger. Both...more

Mayer Brown

DOJ’s Criminal Division Updates Policy on 3 Key Topics: Artificial Intelligence, Whistleblower Programs, and Compliance Program...

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On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri (PDAAG), speaking at the Society of Corporate Compliance and Ethics Annual Compliance & Ethics Institute, announced three key updates to...more

Womble Bond Dickinson

DOJ Updates Its Corporate Compliance Programs Guidance

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On September 23, 2024, the Criminal Division of the U.S Department of Justice (“DOJ”) released revised Evaluation of Corporate Compliance Programs guidance (“September 2024 Guidance), last updated in March 2023....more

The Volkov Law Group

DOJ Issues New FCPA Declination: Boston Consulting Group Pays $14.4 Million

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The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination.  But even a declination comes with a requirement — the company has...more

The Volkov Law Group

Tracking FCPA Individual Enforcement

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While FCPA enforcement against companies has been relatively quiet this year, despite a strong beginning to the year — the SAP case for $220 million; and the Gunvor case for $661 million — DOJ has been pushing a number of...more

Thomas Fox - Compliance Evangelist

Lessons on Ongoing Monitoring and Continuous Improvement from Star Trek: Spectre of the Gun

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 43 - New Horizons: Impact of Recent Appellate Circuit Rulings on White-Collar...

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From circuit courts to the Supreme Court, rulings from appellate courts have turned some tried-and-true principles of law on their head in 2024. How have the decisions affected the practice of white-collar criminal defense...more

Alston & Bird

“No One Wants to Be Second”: The DOJ’s New Corporate Whistleblower Awards Pilot Program

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The DOJ’s much-anticipated corporate whistleblower program is here, making multimillion-dollar financial awards available to eligible individuals who report corporate misconduct. There’s lots in it to digest, and our White...more

Thomas Fox - Compliance Evangelist

The Foreign Corrupt Practices Handbook: Interview with the Authors

I recently spoke with the Foreign Corrupt Practices Act (FCPA) Handbook authors Robert Tarun and Peter Tomczak from Baker McKenzie for a two-part podcast episode. The depth of knowledge and experience in white-collar crime,...more

Epiq

Compliance Programs Under Scrutiny

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In today’s regulatory environment, corporations have a heightened obligation to investigate potential wrongdoing by their employees and to monitor, and possibly disclose, incidents of illegal conduct....more

The Volkov Law Group

Episode 324 -- Third-Party Risks and Sanctions Compliance

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With the beginning of the “New FCPA” era coined by DOJ’s Deputy Attorney General Lisa Monaco, we now need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important and not just...more

The Volkov Law Group

DOJ Heralds New Voluntary Self-Disclosure Program for Individuals

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On April 15, 2023 Nicole Argentieri, Principal Deputy Assistant Attorney General and the Head of the U.S. Department of Justice’s (“DOJ’s”) Criminal Division, announced a new voluntary self-disclosure program for individuals...more

Woods Rogers

Wax On, Wane Not: Corporate Investigations and Enforcement Actions are on the Rise at DOJ

Woods Rogers on

Every national election cycle, we are reminded that presidential administrations drive the trajectory of white-collar civil and criminal enforcement priorities. Halfway through President Biden’s first term, in 2022, Attorney...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the...

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In a single decade, the prosecutions of those accused of white-collar crime underwent a radical transformation. This thought-provoking episode will take you back in time to explore the DOJ's approach in the early 2000s Enron...more

The Volkov Law Group

Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement

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On the heels of the Gunvor FCPA settlement for $661 million, DOJ announced its settlement with Trafigura, the latest commodities trading company to fall under DOJ's FCPA Sweep against the industry.  Trafigura joined the list...more

Thomas Fox - Compliance Evangelist

DAG Monaco at ABA White Collar Conference: Self-Disclosure, Wanted Posters and AI

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

Thomas Fox - Compliance Evangelist

The Gunvor FCPA Enforcement Action: Part 3-the Discounted Fine

We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm Gunvor S.A. The enforcement action came in with a $661 million penalty against the company, which has pleaded...more

White & Case LLP

DOJ Doubles Down on Warnings Against AI Misuse

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In February 2024, we published an alert concerning the increase in regulatory attention to "AI washing," or making unfounded claims regarding artificial intelligence ("AI") capabilities. Notably, on February 14, 2024,...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 2, the Need for Speed

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

The Volkov Law Group

DOJ’s New Mantra — Data and Detection

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The technology revolution and the rise of information and data permeates every aspect of our economy and daily lives.  It is not surprising then that the Department of Justice and other law enforcement agencies are embracing...more

A&O Shearman

Corficolombiana Pays $80M To Resolve Bribery Probes

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On August 10, 2023, the U.S. Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), in coordination with Columbian authorities, announced that Colombian conglomerate Grupo Aval Acciones y Valores S.A...more

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