The Department of Justice Antitrust Division will now consider a target company’s antitrust compliance program when determining how to resolve criminal matters. This represents a fundamental shift in the Antitrust Division’s...more
9/6/2019
/ Antitrust Division ,
Antitrust Provisions ,
Antitrust Violations ,
Chief Compliance Officers ,
Compliance ,
Cooperation ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Federal Sentencing Guidelines ,
New Guidance ,
Risk Assessment ,
White Collar Crimes
On May 7, 2019, the Department of Justice (DOJ) released guidance for civil prosecutors in determining how to assess cooperation in False Claims Act (FCA) cases. See DOJ’s press release and its revised manual. In particular,...more
This week, the Fraud Section of the Department of Justice (DOJ) announced a pilot program that extends additional “mitigation credit” to qualifying companies that “fully cooperate” in matters involving the Foreign Corrupt...more
4/9/2016
/ Bribery ,
Compliance ,
Cooperation ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Individual Accountability ,
Internal Investigations ,
Popular ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes ,
Yates Memorandum
The Department of Justice (DOJ) long has required entities seeking credit for cooperating with its investigations to provide what it terms “full and truthful” cooperation. In policies memorialized over time, DOJ has been...more
9/18/2015
/ Cooperation ,
Corporate Crimes ,
Corporate Veil ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Government Investigations ,
Guidance Update ,
Individual Accountability ,
Internal Investigations ,
Non-Prosecution Agreements ,
Personal Liability ,
Policy Statement ,
Professional Misconduct ,
White Collar Crimes ,
Yates Memorandum