News & Analysis as of

Cooperation Department of Justice (DOJ)

Thomas Fox - Compliance Evangelist

The Boston Consulting Group Declination: A Money Shot for Clawbacks

In a recent development that has garnered significant attention in the compliance community, the U.S. Department of Justice (DOJ) declined prosecution of Boston Consulting Group, Inc. (BCG) for violations of the Foreign...more

WilmerHale

DOJ Rolls Out Corporate Whistleblower Pilot Program

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On August 1, 2024, the Department of Justice officially launched a three-year pilot program to reward whistleblowers who report corporate misconduct....more

Latham & Watkins LLP

10 Key Takeaways Developments in International Cartel Enforcement and Observations From Workshop

Latham & Watkins LLP on

Latham’s Antitrust & Competition Practice provides insight on the current state of enforcement, including more expansive views of what constitutes a cartel, enhanced detection tools, and what to expect next....more

WilmerHale

Antitrust Division’s Implementation of the Department of Justice’s Safe Harbor Declination Policy - A Policy in Search of a Fact...

WilmerHale on

The Antitrust Division of the Department of Justice quietly made a change to its Leniency Policy and Procedures (the “Leniency Policy”) that could impact companies acquiring businesses or companies that they discover may have...more

BakerHostetler

SEC Enforcement Director Grewal Doubles Down on Encouraging Self-Reporting

BakerHostetler on

In a recent interview with Law360, Securities and Exchange Commission (SEC) Enforcement Director Gurbir Grewal reiterated the agency’s commitment to the encouragement of voluntary self-reporting, going as far as to say that...more

Snell & Wilmer

The Department of Justice Offers Individual Corporate Wrongdoers a “Get Out of Jail Free Card” in New Voluntary Self-Disclosure...

Snell & Wilmer on

The Department of Justice’s Criminal Division (DOJ) recently announced a Pilot Program on Voluntary Self-Disclosures for Individuals (the Individual VSD Pilot Program or Pilot Program), which allows certain individuals...more

The Volkov Law Group

DOJ Heralds New Voluntary Self-Disclosure Program for Individuals

The Volkov Law Group on

On April 15, 2023 Nicole Argentieri, Principal Deputy Assistant Attorney General and the Head of the U.S. Department of Justice’s (“DOJ’s”) Criminal Division, announced a new voluntary self-disclosure program for individuals...more

Robinson & Cole LLP

Department of Justice Criminal Division Announces Voluntary Self-Disclosure Pilot Program for Culpable Individuals

Robinson & Cole LLP on

Last week, the Department of Justice (DOJ) announced the Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals (the Program). Pursuant to the Program, “an individual who voluntarily self-discloses...more

Mintz

DOJ’s Criminal Division Announces Pilot Program on Voluntary Self-Disclosure for Individuals

Mintz on

Drawing on a carrot and stick approach, Department of Justice (“DOJ” or the “Department”) guidance in 2023 focused heavily on incentivizing companies to voluntarily self-disclose their misconduct. This guidance included the...more

Venable LLP

DOJ Announces Pilot Program for Individual Voluntary Self-Disclosures

Venable LLP on

On April 15, 2024, the Department of Justice (DOJ) criminal division announced a new pilot program designed to reward individuals with non-prosecution agreements (NPAs) who voluntarily self-disclose "actionable, original...more

Dorsey & Whitney LLP

DOJ’s Criminal Division Launches New Self-Disclosure Pilot Program for Individuals

Dorsey & Whitney LLP on

On April 15, 2024, the U.S. Department of Justice (DOJ)’s Criminal Division announced a new pilot program that will allow and encourage individuals involved in specific types of corporate criminal conduct to voluntarily...more

BakerHostetler

DOJ’s Criminal Division Announces New Pilot Program onVoluntary Self-Disclosure for Individuals

BakerHostetler on

Under the newly announced pilot program, individuals who fully cooperate and voluntarily provide the Criminal Division with information on certain types of corporate and white-collar offenses may receive an NPA in exchange...more

Fisher Phillips

Workplace Law Update: 10 Essential Items on Your April To-Do List

Fisher Phillips on

It’s hard to keep up with all the recent changes to labor and employment law, especially since the law always seems to evolve at a rapid pace. In order to ensure you stay on top of the latest changes and have an action plan...more

Fisher Phillips

Feds Encourage Companies to Come Clean on Criminal Conduct and Reward Whistleblowers for Reporting Wrongdoing: Key Takeaways for...

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Federal prosecutors are exploring new ways to encourage business leaders to invest in their corporate compliance programs. Indeed, a Department of Justice official recently announced several new programs incentivizing...more

ArentFox Schiff

Compulsory Corporate Monitorships: Strategies for Success

ArentFox Schiff on

Numerous regulatory jurisdictions internationally, as well as multiple nongovernmental organizations (NGOs) such as the World Bank, have increasingly used compulsory corporate monitorships as part of their respective...more

BakerHostetler

The Lines Are Open! DOJ Adds New Tool in Anticorruption Efforts With Whistleblower Pilot Program

BakerHostetler on

Building on the recent passage of the Foreign Extortion Prevention Act (FEPA), at the American Bar Association’s 2024 National Institute on White Collar Crime conference in San Francisco earlier this month (2024 ABA...more

Goodwin

In Continuing Efforts to Incentivize Self-Disclosures and Cooperation, DOJ Announces Pilot Program to Pay Criminal Whistleblowers

Goodwin on

Over the last few years, the U.S. Department of Justice (“DOJ”) has continuously announced significant policies and programs directed at encouraging and rewarding the timely reporting of corporate wrongdoing, incentivizing...more

Tucker Arensberg, P.C.

U.S. Department of Justice (DOJ) Provides Corporate Fraud Enforcement Update

Tucker Arensberg, P.C. on

During the American Bar Association’s 39th National Institute on White Collar Crime, the most senior executives of the DOJ (Attorney General Merrick B. Garland and Deputy Attorney General Lisa Monaco) delivered remarks...more

BakerHostetler

DOJ to Corporations - “Knock on Our Door Before We Knock on Yours”

BakerHostetler on

At last week’s ABA National White Collar Crime Institute, the leadership of the Department of Justice (the DOJ or the Department), including Attorney General Merrick Garland and Deputy Attorney General Lisa Monaco, made clear...more

American Conference Institute (ACI)

The Foreign Extortion Prevention Act: Much Ado About Nothing?

In December 2023, President Joe Biden signed the Foreign Extortion Prevention Act (FEPA) into law under the broader Fiscal Year 2024 National Defense Authorization Act (NDAA). While FEPA’s sponsors hailed it as “the most...more

Thomas Fox - Compliance Evangelist

Self-Disclosure is Now the Key

The Department of Justice (DOJ) has been making significant strides in emphasizing the importance of voluntary self-disclosure in corporate enforcement cases, particularly in the realm of the Foreign Corrupt Practices Act...more

Mintz

EnforceMintz — DOJ’s Efforts in 2023 to Incentivize Voluntary Self-Disclosure

Mintz on

2023 was a very active one for Department of Justice (DOJ or the “Department”) guidance, and that guidance had one clear theme: DOJ wants companies to voluntarily self-disclose their misconduct. To incentivize...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2023 Developments and Predictions for 2024

WilmerHale on

Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more

American Conference Institute (ACI)

[Event] Mexico Summit on Anti-Corruption & Compliance Program - March 13th - 14th, Mexico City, Mexico

ACI’s Mexico Summit on Anti-Corruption & Compliance Programs returns on March 13-14, 2024 in Mexico City! Given the uncertainty with the looming Presidential election, as well as increased U.S. enforcement focus on Mexico...more

Eversheds Sutherland (US) LLP

SDNY announces new whistleblower program, continuing Justice’s push for self-disclosure

“Call us before we call you.” With this message, on January 10, 2024, the Southern District of New York announced the SDNY Whistleblower Pilot Program (Pilot Program), which seeks to encourage individual participants in...more

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