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Criminal Prosecution Compliance Individual Accountability

Axinn, Veltrop & Harkrider LLP

Conspiracy Theories Newsletter, 2024 Edition: Eight Predictions for the Future of Cartel Enforcement

2023 was a dramatic year for criminal antitrust enforcement in the United States. The Antitrust Division of the U.S. Department of Justice (“DOJ”) garnered big wins: three convictions at trial,1 $267 million in criminal fines...more

Brownstein Hyatt Farber Schreck

DOJ Rolls Out Corporate Self-Disclosure Policy to Be Enforced by U.S. Attorney’s Offices

On Feb. 22, 2023, the U.S. Department of Justice announced a new Voluntary Self-Disclosure Policy to encourage self-disclosure of potential criminal activity in exchange for varying levels of amnesty from criminal charges....more

Foodman CPAs & Advisors

Corporate Crime At The Forefront Of The DOJ

On September 15, 2022, Department of Justice (DOJ) Deputy Attorney General Lisa Monaco delivered remarks on Corporate Criminal Enforcement at the NYU Program on Corporate Compliance and Enforcement and announced new guidance...more

Dorsey & Whitney LLP

DOJ Paving a More Structured Path for Corporate Criminal Enforcement

Dorsey & Whitney LLP on

​​​​​​​On September 15, 2022, Deputy Attorney General Lisa Monaco laid out the DOJ’s first substantive changes to white-collar criminal investigations and enforcement under the Biden administration....more

BakerHostetler

Attorney General Merrick Garland Emphasizes Criminal Corporate Enforcement and Individual Accountability

BakerHostetler on

On March 3, 2022, Attorney General Merrick B. Garland delivered a speech at the ABA Institute on White Collar Crime that underscored the Department of Justice’s (DOJ) commitment to prosecuting corporate crime and holding...more

Holland & Knight LLP

AG Merrick Garland: DOJ Prioritizing Prosecution of Individuals in White Collar Crime

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In remarks to the American Bar Association (ABA) Institute on White Collar Crime on March 3, 2022, Attorney General Merrick Garland underscored the U.S. Department of Justice's (DOJ) renewed emphasis on corporate...more

Sheppard Mullin Richter & Hampton LLP

Feds Focus on Individuals in Evaluating Corporate Compliance Programs

Earlier this month, the U.S. Department of Justice (“DOJ”) and the U.S. Department of the Treasury’s Office of Foreign Asset Controls (“OFAC”) both issued guidance regarding their expectations for corporate compliance...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2019 Insights: DOJ Policies Aim to Reduce Enforcement Burden on Cooperating Entities

The Department of Justice (DOJ) appears to be continuing to revamp its approach to companies suspected of financial crimes, and emphasize the importance of prosecutions of individuals. In a number of speeches in 2018, senior...more

Ruder Ware

Sally Yates’ was Already Famous for Changing the Focus of Compliance Investigations - The Yates Memorandum

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By now the whole world knows about Sally Yates. We are likely to see a lot more of her as a central figure in Congressional investigations. For some of us who deal with compliance investigations, Sally Yates was famous long...more

Pillsbury Winthrop Shaw Pittman LLP

New FCPA Self-Reporting Pilot Program Formalizes Rewards but Relies on Discretionary Implementation

On April 5, 2016, the Department of Justice unveiled a one-year pilot program designed to encourage companies to self-report violations of the Foreign Corrupt Practices Act (the FCPA). Built upon the Department’s September 9,...more

Parker Poe Adams & Bernstein LLP

Is Confession Good for the Corporate Soul?: DOJ announces new mitigation credit for self-disclosure of FCPA violations

On April 5, 2016, the Department of Justice’s (“DOJ”) Fraud Section Chief, Andrew Weissmann, issued a memo (the “Weissmann Memorandum”) announcing a one-year Pilot Program that offers a carrot and stick approach to...more

WilmerHale

DOJ Launches FCPA Pilot Program to Encourage Corporate Voluntary Disclosure and Cooperation

WilmerHale on

On April 5, 2016, the Fraud Section of the Department of Justice's (DOJ) Criminal Division issued an enforcement plan and guidance (the Guidance) laying out three steps it is taking to intensify Foreign Corrupt Practices Act...more

Foley & Lardner LLP

DOJ Fraud Section Offers Super Credit in FCPA Pilot Program

Foley & Lardner LLP on

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

Dorsey & Whitney LLP

DOJ Announces One-Year FCPA Enforcement Pilot Program

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The U.S. Department of Justice (“DOJ”) Criminal Division yesterday announced that its Fraud Section’s Foreign Corrupt Practices Act (“FCPA”) Unit is conducting a one-year FCPA enforcement pilot program (“Program”). A company...more

BCLP

DOJ’s “Half Off” Deals for Self-Reporting FCPA Misconduct: Certain Exclusions Apply, See Below for Details

BCLP on

For the next year, the Justice Department may be offering up to a 50% discount on fines imposed in FCPA cases. Yesterday, the U.S. Department of Justice’s (“DOJ”) Criminal Division announced the launch of a one-year pilot...more

Proskauer - Corporate Defense and Disputes

Criminal Division Launches New FCPA Pilot Program

On April 5, 2016, the Department of Justice upped the ante in its efforts to encourage companies to self-report potential Foreign Corrupt Practices Act (“FCPA”) violations when it unveiled a one-year pilot program that...more

Dorsey & Whitney LLP

DOJ’s New FCPA Pilot Program: The Offer of Enhanced Credit

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DOJ’s continuing focus on individuals has spawned a new one year FCPA Pilot Program which offers companies enhanced cooperation credit The new Pilot Program is part of an overall effort to bolster FCPA compliance. Those...more

The Volkov Law Group

Misconduct in the C-Suite: SEC Settles FCPA Case with CEO

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The SEC is setting its sights on individual prosecutions. Both the Justice Department and the SEC have reiterated the importance of prosecuting individuals. DOJ’s Yates Memorandum promises to deliver an increase in civil and...more

McDermott Will & Emery

Focus on China - October 2015

McDermott Will & Emery on

Welcome to the third issue of Focus on China Compliance for 2015. According to the FCPA Blog’s October 2015 Corporate Investigations List, China leads the countries reported to be involved in FCPA investigations with 29...more

Holland & Knight LLP

DOJ Targets Executives and Individuals in Corporate Investigations

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Responding to criticism stemming from a lack of individual prosecutions as a result of the financial crisis, Deputy Attorney General Sally Yates has issued a new guidance memorandum establishing six new steps for federal...more

Proskauer - Corporate Defense and Disputes

Justice Department Prioritizes Prosecution of Individuals for Corporate Misconduct in New Guidance

After prolonged criticism over its lack of prosecution of individuals responsible for corporate misconduct, the Justice Department has issued new internal guidance that makes clear that prosecuting individuals in white collar...more

Alston & Bird

“Individual Accountability for Corporate Wrongdoing”: The Yates Memo and the DOJ’s Focus on Individuals

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On September 9, 2015, the Department of Justice issued a memo (“Individual Accountability for Corporate Wrongdoing”) to federal prosecutors nationwide implementing new policies that—for the first time—prioritize the...more

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