ANTICORRUPTION DEVELOPMENTS -

Deputy Assistant Attorney General Matt Miner Delivers Remarks at the American Bar Association, Criminal Justice Section Third Global White Collar Crime Institute Conference -

On June 27, 2019, Deputy Assistant Attorney General Matt Miner gave a speech to the ABA’s Third White Collar Crime Institute Conference in Prague, Czech Republic. In addition to discussing recent enforcement actions and convictions (see below) as well as the Department of Justice’s (DOJ) continued cooperation with its international counterparts, Miner addressed the topic of declinations. Specifically, Miner noted that declinations will not always be made public: “For instance, if a company self-discloses misconduct that was discovered in the context of a merger or acquisition, and we determine that the conduct and financial impact was de minimis, we may be open to a company’s request that we not disclose the declination.” Miner acknowledged that there are instances where DOJ may decline to exercise their authority investigate conduct occurring abroad and/or involving foreign entities where the Department “determine[s] that no significant federal interest is at stake, or that the matter is better handled by a foreign authority.”