News & Analysis as of

Corporate Governance Self-Reporting

The Volkov Law Group

SEC Outlines “Effective Cooperation” Standard

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The Securities and Exchange Commission is catching up to DOJ.  Not in enforcement but in transparency. After years of criticism, the Justice Department has set the gold standard for transparency and providing guidance on...more

Perkins Coie

DOJ Announces Whistleblower Awards Pilot Program and Introduces 120-Day Window for Corporate Self-Disclosures

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The U.S. Department of Justice (DOJ or the Department) announced its much-anticipated Corporate Whistleblower Awards Pilot Program on August 1, 2024. This three-year pilot will, for the first time outside of the False Claims...more

Kohn, Kohn & Colapinto LLP

The Double-Edged Impact of AI Compliance Algorithms on Whistleblowing

As the implementation of Artificial Intelligence (AI) compliance and fraud detection algorithms within corporations and financial institutions continues to grow, it is crucial to consider how this technology has a twofold...more

Society of Corporate Compliance and Ethics...

Don’t be afraid

A recent issue of SCCE’s Corporate Compliance Weekly News contained a link to a startling report I was not previously familiar with. An investigation by the U.S. Coast Guard found numerous instances of sexual assault spanning...more

Vinson & Elkins LLP

New CFTC Enforcement Policy Increases Penalties to Deter Recidivists

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The U.S. Commodity Futures Trading Commission (“CFTC” or “Commission”) — the federal agency tasked with regulating the U.S. derivatives markets, which includes futures, swaps and certain kinds of options — has recently taken...more

Skadden, Arps, Slate, Meagher & Flom LLP

2024 Insights: Enforcement and Litigation

Expert Allegations Could Become More Frequent in Securities Fraud Complaints and Possibly Erode Pleading Standards - A Ninth Circuit panel ruling that plaintiffs could use expert analysis to bolster securities fraud claims...more

Sheppard Mullin Richter & Hampton LLP

DOJ Touts Emerging Results from New Corporate Crime Self-Reporting Initiatives

The Department of Justice’s recent criminal self-reporting policy changes are beginning to show results, according to Assistant Attorney General Kenneth Polite Jr. Speaking at the New York City Bar Association’s White Collar...more

Holland & Knight LLP

Executive Perks: A Hammer Finds Its Nail in SEC Settlement with Tool Company

Holland & Knight LLP on

We return once more to the issue of public company executive perquisites or "perks" – a topic we anticipated last year would "be a hot-button enforcement issue for the foreseeable future." We were not wrong. In light of the...more

Baker Donelson

Companies Take Heed: DOJ Announces Key Updates and Corporate Compliance Guidance

Baker Donelson on

On March 3, 2023, Assistant Attorney General Kenneth Polite delivered the keynote speech at the 38th Annual National Institute on White Collar Crime of the American Bar Association (ABA) in Miami, Florida. AAG Polite's speech...more

Arnall Golden Gregory LLP

Government Investigations Team Insights - February 2023

AGG’s Government Investigations Team Insights provides periodic updates covering legal and regulatory topics. Our team, which includes former federal prosecutors, SEC enforcement attorneys, and federal agency attorneys, has...more

Conn Kavanaugh

“Corporate Citizen, Police Thyself”: How the DOJ Is Changing Its Corporate Enforcement Policy to Encourage Self-Policing

Conn Kavanaugh on

Self-Reporting Remains a Major Focus - Few executives expect to interact with the Department of Justice (DOJ) during their careers, but the current DOJ has given companies some homework, and the assignment applies to...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Doubles Down on Efforts To Incentivize Early Self-Reporting and Cooperation

On January 17, 2023, the U.S. Department of Justice (DOJ) announced revisions to the Criminal Division’s Corporate Enforcement Policy. The revisions follow Deputy Attorney General (DAG) Lisa Monaco’s September 2022...more

Foodman CPAs & Advisors

El FCPA Y El CPA

El cumplimiento del FCPA (Ley de Prácticas Corruptas en el Extranjero, “Foreign Corrupt Practices Act) debe estar a la vanguardia de las empresas de todos los tamaños en todas las industrias....more

Vinson & Elkins LLP

DOJ Chooses Sticks Over Carrots: Three Reasons Why Changes to DOJ’s Corporate Enforcement Policy May Chill Cooperation by...

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In announcing recent changes to its corporate criminal enforcement policies, the Department of Justice (“DOJ” or the “Department”) continued its forceful “tough on crime” initiatives to deter wrongdoing....more

Husch Blackwell LLP

DOJ's New Policies Encourage Voluntary Self-Disclosure, Compensation Tied to Compliance

Husch Blackwell LLP on

In a speech given at NYU on September 15, 2022, Deputy Attorney General Lisa Monaco reviewed new and enhanced Department of Justice (DOJ) policies regarding criminal enforcement related to corporate entities. Assistant...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

DOJ Reveals New Corporate Enforcement Strategy

Takeaway: Changes in DOJ corporate compliance programs focus on prompt reporting and self-disclosure, and individual accountability. Companies can protect their interests by creating a diligent, comprehensive risk-based...more

NAVEX

Another Reminder About a Commitment to Compliance

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The U.S. Justice Department has long said (and compliance officers have said it too) that a culture of compliance is what matters in regulatory enforcement actions, and can pay dividends in the form of smaller monetary...more

Dechert LLP

No Reward for Good Behaviour: The Central Bank’s approach to enforcement

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On 14 November 2019, the Central Bank of Ireland (the “Central Bank”) launched its Administrative Sanctions Guidance (the “Guidance”), accompanied by a key-note speech by Derville Rowland, the Director General of Financial...more

NAVEX

The Future of U.K. Enforcement of Financial Crimes: Four Clues for 2015

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The legal and compliance landscape is changing quickly—it’s up to organisations that do business in the U.K. to strengthen their compliance programmes to meet these new challenges. In this whitepaper, Andrew Foose, vice...more

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