News & Analysis as of

White Collar Crimes Corporate Misconduct Corporate Counsel

Carlton Fields

DOJ Policy Changes Have Made Internal Investigations More Important Than Ever

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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

WilmerHale

DOJ Announces White Collar Enforcement Priorities and Revisions to Related Policies

WilmerHale on

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

Hogan Lovells

SFO's new self-reporting guidance: A new deal or a departure from justice?

Hogan Lovells on

On 24 April 2025, the Serious Fraud Office (SFO) issued new guidance signalling a notable shift in its approach to corporate criminal enforcement. For the first time, the SFO has stated that if a company self-reports...more

Paul Hastings LLP

Keep Calm and Carry On: Thoughts on Recent Orders on FCPA Enforcement

Paul Hastings LLP on

What in the world is happening with enforcement of the Foreign Corrupt Practices Act (FCPA)? And what does the recent executive order (EO) and Department of Justice (DOJ) guidance mean for U.S. and global companies? Our view...more

BCLP

Crime-Fraud Exception Destroys Privilege for Communications Between Former CEO of Public Company and His Outside Lawyer

BCLP on

On February 7, 2025, the Second Circuit ruled that the crime-fraud exception would prevent the  former CEO of a public company from invoking attorney-client privilege to prevent an outside lawyer and his law firm from...more

WilmerHale

FCPA Year-in-Review: 2024 Developments and Predictions for 2025

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Foreign Corrupt Practices Act (FCPA) enforcement activity increased overall in 2024, with a notable uptick in Department of Justice (DOJ) enforcement actions compared to 2023, despite a decrease in public Securities and...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for December 2024

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

Thomas Fox - Compliance Evangelist

Why the 2024 ECCP Update is a Game-Changer for Compliance

In the DOJ’s 2024 update to the Evaluation of Corporate Compliance Programs (2024 ECCP), compliance professionals face new expectations that could reshape how we approach compliance programs. In this latest update, the DOJ...more

BakerHostetler

7 More US Attorneys’ Offices Issue Whistleblower Non-Prosecution Pilot Programs

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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

The Volkov Law Group

John Deere Reaches $9.9 Million Settlement with SEC over FCPA Violations

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The U.S. Securities and Exchange Commission (“SEC”) recently instituted proceedings against Deere & Company (“John Deere”), a leading global manufacturer of agricultural and heavy machinery, for multiple violations of the...more

McDermott Will & Emery

DOJ Unveils Details of Corporate Whistleblower Awards Pilot Program

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

Wilson Sonsini Goodrich & Rosati

National Security Division’s Voluntary Self-Disclosure Policy in Action: Exchanging Cooperation for Declination

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

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Previews M&A-Focused Guidance on Voluntary Self-Disclosure of Corporate Misconduct

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

Akin Gump Strauss Hauer & Feld LLP

New DOJ Focus on Executive Compensation in Resolving Criminal Investigations

Key Points - The DOJ recently announced several policy updates tethering resolution of criminal investigations to a company’s compensation and bonus programs. These updates include executive compensation focused...more

Fox Rothschild LLP

DOJ Formalizes Framework for Corporate Cooperation Credit

Fox Rothschild LLP on

The Department of Justice (DOJ) announced a new voluntary self-disclosure policy February 22, 2023, that sets uniform criteria for how and when prosecutors should reward corporate cooperation in criminal investigations. The...more

NAVEX

The Justice Department Steps Up Its Compliance Message

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The U.S. Justice Department unveiled new policies about how it will prosecute cases of corporate misconduct, offering new incentives for companies whose misconduct includes “aggravating circumstances” to step forward and...more

WilmerHale

DOJ Announces Updates to Corporate Enforcement Policy

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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

Cranfill Sumner LLP

DOJ Announces Revisions to Corporate Criminal Enforcement Policies

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Earlier this month, DOJ announced additional revisions to the Department’s existing policies and practices governing corporate criminal enforcement. Each of these revisions will soon find its way into DOJ’s Justice Manual....more

Foley Hoag LLP - White Collar Law &...

DOJ Updates Policies on Corporate Ethics and Compliance

Last week, Deputy Attorney General Lisa O. Monaco delivered remarks on corporate criminal enforcement, announcing revisions to DOJ’s policies for addressing corporate ethics and compliance matters. These changes reflect an...more

Jenner & Block

Deputy Attorney General Announces Revisions to DOJ's Corporate Criminal Enforcement Policies and Practices

Jenner & Block on

On September 15, 2022, Deputy Attorney General (DAG) Lisa Monaco issued a memorandum and delivered a speech, announcing several revisions to the Department of Justice's (DOJ)’s corporate criminal enforcement policies and...more

Katten Muchin Rosenman LLP

Deputy Attorney General Monaco Reiterates DOJ's Focus on Prosecuting Individuals and Announces New Guidelines for Prosecuting...

On September 15, Deputy Attorney General (DAG) Lisa O. Monaco announced changes to the Department of Justice’s (DOJ) Corporate Criminal Enforcement program. In her speech, DAG Monaco emphasized DOJ’s commitment to prosecuting...more

Womble Bond Dickinson

DOJ Announcements on Corporate Criminal Enforcement: Defining the Carrots and Sticks

Womble Bond Dickinson on

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

Alston & Bird

Second Circuit Presents U.S. Companies Historic Opportunity to Defend Against FCPA Liability

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The Second Circuit has made the government’s formerly straightforward task of assigning vicarious liability to a corporate principal under the Foreign Corrupt Practices Act considerably harder. Our White Collar, Government &...more

The Volkov Law Group

Deciphering FCPA Enforcement Trends

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In following the Justice Department and the Securities Exchange Commission FCPA enforcement actions, I am always reminded of the popular phrase — “reading the tea leaves.” (or “tasseography,” a fortune-telling method based on...more

The Volkov Law Group

What Can We Expect in Future FCPA Enforcement Actions?

The Volkov Law Group on

In the FCPA and white collar defense community, we have seen buckets and buckets of ink spilled on the coming wave of aggressive enforcement.  Justice Department officials have made so many statements about the “new” approach...more

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