News & Analysis as of

Compliance Department of Justice (DOJ) Strategic Enforcement Plan

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Eversheds Sutherland (US) LLP

New nationwide policy marks latest DOJ effort to incentivize voluntary self-disclosure

On February 22, 2023, the US Department of Justice issued a nationwide policy for all US Attorney’s Offices (USAOs) outlining the circumstances in which a company may receive credit for voluntary self-disclosure (VSD)....more

WilmerHale

The Role of Compliance in Government Enforcement

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As recent developments in corporate enforcement indicate, the United States Department of Justice (DOJ) continues to emphasize transparency, cooperation, and the importance of a strong compliance program. Enforcement trends...more

Latham & Watkins LLP

Current Developments in the US: White-Collar Enforcement and trends for 2020

Latham & Watkins LLP on

In the following article we will discuss the current developments and trends for 2020 and outline what EU-based companies with a US presence should look out for in 2020 regarding US white-collar and compliance trends in the...more

Holland & Knight LLP

Leading Federal Officials Offer Advice on How Corporations Can Minimize Law Enforcement Risk

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Holland & Knight, the Florida Chamber of Commerce and the Miami-Dade Beacon Council hosted the Second Annual Florida Enforcement Summit on Nov. 20, 2019. The half-day program focused on informing the business community how to...more

Foley & Lardner LLP

FCPA Notebook: Trends in 2019

Foley & Lardner LLP on

Foley & Lardner LLP’s International Government Enforcement Defense & Investigations team has created its latest FCPA infographic, which presents an overview of some high-level enforcement trends in an easy-to-view,...more

Pillsbury Winthrop Shaw Pittman LLP

Developments Highlight Secondary Liability Risks for Private Funds

DOJ settlement signals need for enhanced False Claims Act scrutiny. Private funds continue to face heightened secondary liability risks arising from their portfolio investments....more

Pillsbury Winthrop Shaw Pittman LLP

DHS’s New Criminal Enforcement Initiative to Prosecute Corporations for Forced Labor

Criminal investigations will target businesses profiting from the importation into the United States of goods made using forced labor. The new criminal enforcement initiative seeks to leverage data about corporate supply...more

BakerHostetler

[Webinar] Cross-Border Regulation and Enforcement: Developments and Trends You Need to Know for 2019 - May 1st, 12:00pm ET

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Join BakerHostetler’s White Collar, Investigations and Securities Enforcement and Litigation team for a complimentary webinar on trends and predictions for 2019 in the cross-border government investigations and enforcement...more

Latham & Watkins LLP

CFTC Enters the Market for Anti-Corruption Enforcement

Latham & Watkins LLP on

New enforcement advisory encourages reporting of foreign corrupt practices that the agency intends to pursue under the Commodity Exchange Act. On March 6, 2019, the Division of Enforcement (Division) of the US Commodity...more

WilmerHale

Foreign Corrupt Practices Act Alert: Global Anti-Bribery Year-in-Review: 2018 Developments and Predictions for 2019

WilmerHale on

Despite predictions of a slow-down in enforcement under the Trump administration—and indications that enforcement in some areas has decreased in the past year1—2018 was yet again an active year for FCPA enforcement. The year...more

A&O Shearman

FCPA Digest - Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act - January 2019

A&O Shearman on

INTRODUCTION: RECENT TRENDS AND PATTERNS IN FCPA ENFORCEMENT - Although FCPA enforcement across the 2018 calendar year seemed to ebb and flow, in retrospect the enforcement agencies brought a typical number of enforcement...more

WilmerHale

The Serious Fraud Office – Where Next in 2019?

WilmerHale on

Speaking at The Lawyer’s Managing Risk and Litigation 2018 Conference recently, Matthew Wagstaff, Joint Head of Bribery and Corruption at the Serious Fraud Office (“SFO”), outlined the agency’s current priorities and future...more

Jackson Lewis P.C.

[Webinar] 2018 Update: Anti-Corruption Compliance Enforcement and Trends - November 15th, 2:00pm ET

Jackson Lewis P.C. on

The number of prosecutions under the Foreign Corrupt Practices Act (FCPA) remains steady, despite early questions about enforcement under the current administration. Additionally, the new EU General Data Protection Regulation...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2017 Developments and Predictions for 2018

WilmerHale on

This past year marked the 40th anniversary of the U.S. Foreign Corrupt Practices Act (“FCPA”). Since its enactment in 1977, the U.S. Department of Justice (the “DOJ”) has brought approximately 300 FCPA enforcement actions,...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

Latham & Watkins LLP

Deputy Attorney General Announces Comprehensive Review of DOJ Corporate Enforcement Policies

Latham & Watkins LLP on

Key Points: - DOJ is reviewing and reevaluating numerous corporate enforcement policies, including the “Yates Memo,” the FCPA Pilot Program, and policies on corporate monitors. - Policies will be codified in official...more

WilmerHale

Evaluating FCPA Pilot Program: Lessons And Expectations

WilmerHale on

On April 5, 2016, the U.S. Department of Justice released a nine-page memorandum launching a one-year pilot program to reward companies that voluntarily self-report violations of the Foreign Corrupt Practices Act. Now...more

The Volkov Law Group

DOJ’s New FCPA Enforcement Plan and Guidance (Part I of II)

The Volkov Law Group on

The Justice Department finally released its long-awaited new FCPA enforcement plan. It took DOJ a little while to come up with this and in the end, like most initiatives, there is a mixed bag for global companies, FCPA...more

Thomas Fox - Compliance Evangelist

Who is Responsible for Complying with the FCPA?

The Department of Justice (DOJ) still faces criticism over its Foreign Corrupt Practices Act (FCPA) enforcement strategy. Some decry that it is too aggressive, that the DOJ has moved into waters Congress never intended the...more

Thomas Fox - Compliance Evangelist

Welcome to COSO and the World of Internal Controls – Part I

I have intentionally avoided a Top Five or Top Ten prediction list for Foreign Corrupt Practices Act (FCPA) enforcement going forward from 2014 into 2015. However there is one area of FCPA enforcement, which I think underwent...more

Skadden, Arps, Slate, Meagher & Flom LLP

"United States: International Cooperation, Anti-Corruption and Tax Remain Key Issues for Enforcement Authorities"

U.S. authorities continue to aggressively pursue cross-border investigations and to scrutinize closely the compliance programs of multinational corporations. Investigative activity by U.S. authorities in 2014 was particularly...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 121-FCPA Year in Review, Part II

In this episode I review the two Opinion Releases, Esquenazi court decision, DOJ communications via speeches on FCPA enforcement. I end with a look at 2015. ...more

Akin Gump Strauss Hauer & Feld LLP

DOJ and SEC Officials Focus on Enforcement, Self-Reporting and Compliance at International FCPA Conference

From November 18 to 19, 2014, the American Conference Institute held its annual U.S. Foreign Corrupt Practices Act (FCPA) conference outside of Washington, D.C. Keynote speakers including U.S. Department of Justice (DOJ)...more

BakerHostetler

Clear Expectations: DOJ Outlines Tenets of an Effective Antitrust Compliance Program

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There has never been a greater emphasis on policing anticompetitive behavior worldwide. Dozens of countries have instituted effective and aggressive cartel enforcement programs following a trend of increased global...more

Brooks Pierce

Securities Enforcement Forum 2014 — FCPA, SEC/DOJ Joint Actions, and Other Recent Criminalization Trends

Brooks Pierce on

Today I’m blogging from Securities Enforcement Forum 2014, Bruce Carton’s excellent one-day conference, this year being held at the Four Seasons hotel in Washington, D.C. The posts will be fairly raw, and certainly not...more

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