News & Analysis as of

White Collar Crimes Disgorgement Voluntary Disclosure

A&O Shearman

First DOJ Declination For FCPA Violations Since Renewed Enforcement Guidelines

A&O Shearman on

On August 7, 2025, the United States Department of Justice, Criminal Division, Fraud Section (“DOJ”) issued a declination letter to a U.S.-based insurance company (the “Company”) to resolve alleged violations of the Foreign...more

The Volkov Law Group

Liberty Mutual Pays $4.7 Million for FCPA Declination

The Volkov Law Group on

In the first FCPA declination under the Trump Administration, Liberty Mutual Insurance Company paid $4.7 million in disgorgement and received a declination letter from the Department of Justice. The declination reflects...more

The Volkov Law Group

DOJ Awards Declination to Proterial Cable America for Fraud — Proterial Pays $15.1 Million in Disgorgement

The Volkov Law Group on

DOJ is pushing hard for voluntary disclosures and urging companies to take advantage  of its Voluntary Disclosure Program.  The carrot is significant — a declination in exchange for cooperation, remediation and disgorgement....more

The Volkov Law Group

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

The Volkov Law Group on

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

Corsa Coal Earns Declination and Agreed to Disgorge $1.2 Million

The Volkov Law Group on

The Justice Department has been pushing its voluntary self-disclosure program and changes to its Corporate Enforcement Policy, in an attempt to increase FCPA enforcement cooperation.  The Golden Ring for every company facing...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

K&L Gates LLP

Voluntary Disclosure: Newsflash July 2020

K&L Gates LLP on

A government inquiry can result in serious consequences for a company or individual. Our new podcast series, Voluntary Disclosure—brought to you by the lawyers in our investigations, enforcement, and white collar practice—is...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

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

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

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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