News & Analysis as of

White Collar Crimes Declination Voluntary Disclosure

WilmerHale

New Internal DOJ Guidance on Compensating Victims and Coordinating Corporate Penalties in Parallel Proceedings

WilmerHale on

On June 5, 2025, the Department of Justice (“DOJ”) directed prosecutors to prioritize compensating victims when resolving multiagency investigations involving corporate defendants. ...more

Parker Poe Adams & Bernstein LLP

DOJ's New White-Collar Enforcement Plan Signals Strategic Shift in Corporate Investigations

This week the Department of Justice (DOJ) announced its new approach to corporate criminal enforcement, "Focus, Fairness, and Efficiency in the Fight Against White Collar Crime."...more

Fenwick & West LLP

DOJ Announces Key Revisions to Corporate Enforcement and Voluntary Self-Disclosure Policy

Fenwick & West LLP on

On May 12, 2025, the Head of the Department of Justice’s (DOJ) Criminal Division, Matthew Galeotti, announced a new white collar enforcement plan in a memorandum entitled “Focus, Fairness, and Efficiency in the Fight Against...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

DOJ Launches New Pilot Program to Allow Whistleblowers Who Report Financial Crimes, Corruption to Avoid Prosecution

On April 15, 2024, the U.S. Department of Justice (DOJ) Criminal Division launched a new pilot program to enable whistleblowers to avoid prosecution when they voluntarily report new information to federal law enforcement...more

Latham & Watkins LLP

DOJ’s Updated Corporate Enforcement Policy Aims to Incentivize Compliance

Latham & Watkins LLP on

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

Dorsey & Whitney LLP

DOJ Announces Additional Incentives for Corporate Cooperation in Criminal Enforcement

Dorsey & Whitney LLP on

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

Eversheds Sutherland (US) LLP

DOJ sweetens the deal for companies that “come forward, cooperate, and remediate”

On January 17, 2023, Assistant Attorney General Kenneth A. Polite, Jr. (AAG Polite) announced changes to the Department of Justice’s (DOJ) FCPA Corporate Enforcement Policy (CEP). The CEP, which applies to all Criminal...more

Holland & Knight LLP

DOJ Makes Significant Revisions to Corporate Enforcement Policy

Holland & Knight LLP on

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 Volkov Law Group

DOJ Issues Declination and Disgorgement Under FCPA Corporate Enforcement Policy

The Volkov Law Group on

In a recently released letter, the Justice Department issued a declination to the Insurance Corporation of Barbados Limited (ICBL) for violations of the FCPA under the FCPA Corporate Enforcement Policy. DOJ required ICBL to...more

Parker Poe Adams & Bernstein LLP

Digging Into the Details of New FCPA Guidance From the U.S. Justice Department

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

Farella Braun + Martel LLP

FCPA in the Trump DOJ: Continuing Down the Same Path, with a Little More Heft

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

Williams Mullen

The DOJ’s Revised FCPA Corporate Enforcement Policy: A New Blueprint for Corporate Cooperation and Credit

Williams Mullen on

On November 29, 2017, Deputy Attorney General Rod Rosenstein announced the issuance of a revised FCPA Corporate Enforcement Policy (the “Policy”). Rosenstein announced that the “new policy enables the Department [of Justice]...more

Parker Poe Adams & Bernstein LLP

The DOJ’s Latest Compliance Program Warning

U.S Deputy Attorney General Rod Rosenstein recently announced the Department of Justice’s revised FCPA Corporate Enforcement Policy. The revised Policy is based on the DOJ’s FCPA Pilot Program (in place since April 2016),...more

The Volkov Law Group

Justice Department Resolves Two Cases Under FCPA Pilot Program

The Volkov Law Group on

The Justice Department recently resolved two separate FCPA investigations under its Pilot Program. To be sure, DOJ’s resolution of these two matters reinforces the real and tangible benefits of its Pilot Program....more

Thomas Fox - Compliance Evangelist

A Second Superior Result – CDM Smith Obtains a Declination

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

Troutman Pepper Locke

Lessons Learned from the FCPA Pilot Program's First Six Months

Troutman Pepper Locke on

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

The Volkov Law Group

Double Play, Double Declinations: DOJ Pushes FCPA Pilot Program Benefits

The Volkov Law Group on

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

Thomas Fox - Compliance Evangelist

Declinations and Profits Disgorgement – It Was There All Along

Last week there were two declinations issued by Department of Justice (DOJ) for Foreign Corrupt Practices Act (FCPA) matters. The matters involved two Texas based, privately held companies. The first was HMT LLC (HMT) which...more

The Volkov Law Group

The Power of a Justice Department Declination

The Volkov Law Group on

Tom Fox and I recorded a podcast recently on the Johnson Controls enforcement action. In our podcast we discuss a number of issues relating to the Justice Department’s decision to reward Johnson Controls with a declination....more

Thomas Fox - Compliance Evangelist

Enforcement Week V: Three-Month Pilot Program Wrap Up

Today, I end my exploration of recent Foreign Corrupt Practices Act (FCPA) enforcement actions (and one UK Bribery Act enforcement issue), which have occurred since the enactment of the Department of Justice (DOJ) Pilot...more

Parker Poe Adams & Bernstein LLP

Is Confession Good for the Corporate Soul?: DOJ announces new mitigation credit for self-disclosure of FCPA violations

On April 5, 2016, the Department of Justice’s (“DOJ”) Fraud Section Chief, Andrew Weissmann, issued a memo (the “Weissmann Memorandum”) announcing a one-year Pilot Program that offers a carrot and stick approach to...more

WilmerHale

DOJ Launches FCPA Pilot Program to Encourage Corporate Voluntary Disclosure and Cooperation

WilmerHale on

On April 5, 2016, the Fraud Section of the Department of Justice's (DOJ) Criminal Division issued an enforcement plan and guidance (the Guidance) laying out three steps it is taking to intensify Foreign Corrupt Practices Act...more

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