Fox on Podcasting: Harnessing the Power of Niche
Daily Compliance News: July 17, 2025, The COSO Yanked Edition
All Things Investigation: Due Diligence and Drama: A Deep Dive into Art World with Daniel Weiner
10 For 10: Top Compliance Stories For the Week Ending, July 12, 2025
Daily Compliance News: July 9, 2025, The TACO Don Caves Again Edition
RICO Section 1962(b): Acquisition or Maintenance of Control Over Legitimate Enterprises — RICO Report Podcast
Adventures in Compliance: The Novels – The Hound of the Baskervilles, Introduction and Compliance Lessons Learned
10 For 10: Top Compliance Stories For the Week Ending June 28, 2025
The Dark Patterns Behind Corporate Scandals
FCPA Compliance Report: Fraud Risk Management - Insights and Experiences with Peter Schablik
Episode 374 -- Justice Department Resumes FCPA Enforcement with New, Focused Guidance
Daily Compliance News: June 20, 2025, The Death of the Business Card Edition
Understanding the DOJ's Recent Corporate Enforcement Policy Changes
All Things Investigations: Navigating New DOJ Directives - Declinations, Cooperation, and Whistleblower Programs with Mike DeBernardis and Katherine Taylor
Daily Compliance News: June 16, 2025, The Golden Share Edition
FCPA Compliance Report: Recent DOJ Policy Announcements
An Ounce of Prevention Podcast | The International Anti-Corruption Prosecutorial Taskforce and the Future of Global Enforcement
Everything Compliance: Episode 154, The Law Firms in Trouble Edition
SBR-Author’s Podcast: The Unseen Life of an Undercover Agent: A Conversation with Charlie Spillers
The decision for a company to self-disclose potential criminal misconduct to the U.S. Department of Justice (DOJ) is always complex. This is particularly true during periods of administration transitions when DOJ policies and...more
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
The US Department of Justice (DOJ) revised its Criminal Division Corporate Enforcement and Voluntary Disclosure Policy (CEP), outlining the benefits a company may earn by voluntarily self-disclosing misconduct, as well as the...more
In recently released updated guidance, the Antitrust Division (“Antitrust Division”) of the U.S. Department of Justice (“DOJ”) outlined how its prosecutors will assess corporate compliance programs when conducting criminal...more
We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more
A recent article in Law360 sparked a vigorous conversation among members of Pietragallo’s white collar practice group about the current state of the U.S. Department of Justice’s (DOJ) evolving emphasis on individual...more
Under a new U.S. Department of Justice ("DOJ") policy related to mergers and acquisitions ("M&A"), DOJ will decline to prosecute an acquiring company for misconduct by an acquired company where the acquiring company timely...more
No Longer Just a Matter of Paying the Fine and Moving On. Corporate settlement agreements used to be straightforward—pay the penalty and move on. Now, these resolutions rival complex business transactions, including...more
The Justice Department is on a marketing campaign – pushing a simple message. If your company commits misconduct, come in and confess to the Justice Department. To push this message, DOJ has tinkered with its Corporate...more
Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors. In a speech at Georgetown University Law Center on...more
On Jan. 17, AAG Polite announced “the first significant changes” to the CEP since 2017. The policy revisions will apply to all corporate criminal matters handled by the Criminal Division and offer companies “new, significant,...more
On January 17, 2023, Assistant Attorney General for the United States Department of Justice Kenneth A. Polite Jr. announced significant revisions to the Criminal Division’s Corporate Enforcement Policy (“CEP”). Four months...more
The U.S. Department of Justice (DOJ), through Assistant Attorney General Kenneth A. Polite Jr., announced on Jan. 17, 2023, "the first significant changes" to its Corporate Enforcement Policy (CEP) since 2017. The revisions...more
“The truest measure of an effective compliance program is how it responds to misconduct.”— FCPA Guidance (2d. ed 2020) - This straight-forward statement (above) of a company’s commitment to its “effective” compliance...more
On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more
On March 8, 2019, the U.S. Department of Justice announced an important change to its Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy concerning one of the conditions — “appropriate retention of business...more
Assistant Attorney General Brian Benczkowski’s remarks provide important guidance for management and boards, and underscore the US Department of Justice’s commitment to prosecuting individuals for corporate misconduct....more
Sometimes I get to select the topics I blog on each week and sometimes it seems as if the topics select themselves. It looks like we will have a sports-themed week here on the FCPA Compliance and Ethics Blog. ...more
Next week marks the 40th anniversary of the Foreign Corrupt Practices Act – it became effective December 19, 1977. Deputy Attorney General Rod Rosenstein marked the occasion this month by providing an update on the FCPA Pilot...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
I conclude my five-part series on the soft skills a Chief Compliance Officer (CCO) needs to employ when working through the remediation component of a potential Foreign Corrupt Practices Act (FCPA) compliance violation. I...more
Today I continue a five-part series on the soft skills a Chief Compliance Officer (CCO) needs to employ when working through the remediation component of a potential Foreign Corrupt Practices Act (FCPA) compliance violation....more
There are multiple areas in the Department of Justice’s Evaluation of Corporate Compliance Programs which intersect with the area of continuous improvement. In addition to Prong 9. Continuous Improvement, Periodic Testing and...more
By now the whole world knows about Sally Yates. We are likely to see a lot more of her as a central figure in Congressional investigations. For some of us who deal with compliance investigations, Sally Yates was famous long...more
Today I conclude my two-part series on the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de Chile (SQM), which agreed to pay a...more