News & Analysis as of

White Collar Crimes Internal Controls Voluntary Disclosure

Epiq

The New DOJ Position on Self-Disclosure Demands High-Functioning Compliance

Epiq on

In remarks to an industry group, Matthew R. Galeotti, head of the Department of Justice (DOJ) Criminal Division, emphasized that companies may avoid criminal resolutions if they voluntarily self-disclose misconduct, fully...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 5-Lessons Learned

Over the past several blog posts, I have been exploring the Albemarle FCPA enforcement action.  We have explored in some detail the DOJ Non-Prosecution Agreement (NPA) and the SEC Administrative Order(Order). In this final...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

Snell & Wilmer

The Foreign Corrupt Practices Act’s One-Year “Pilot Program” Nears The Halfway Mark

Snell & Wilmer on

The Foreign Corrupt Practices Act (“FCPA”) prohibits both United States and foreign corporations and nationals from offering or paying, or authorizing the offer or payment, of anything of value to a foreign government...more

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