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Criminal Prosecution Department of Justice (DOJ) Cooperation

BakerHostetler

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

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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

BakerHostetler

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

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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

WilmerHale

Criminal Indictment for Medicare Advantage Fraud

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The U.S. Department of Justice (DOJ) recently announced a rare criminal indictment involving the Medicare Advantage program—a contrast from DOJ’s more typical use of its civil enforcement authority to pursue similar issues...more

Troutman Pepper

The Stick and the Carrot: DOJ Continues to Eye Corporate Crimes, While Encouraging Prompt Self-Disclosures of Misconduct...

Troutman Pepper on

On October 4, Deputy Attorney General (DAG) Lisa Monaco announced the Department of Justice’s (DOJ) new Safe Harbor Policy for voluntary self-disclosures made in connection with mergers and acquisitions (M&A). This policy is...more

Foley Hoag LLP

DOJ Announces New Safe Harbor Policy for Self-Disclosures in Connection with M&A Transactions and Additional Resources for...

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On October 4, 2023, the U.S. Department of Justice (“DOJ”) announced a new Mergers & Acquisitions (“M&A”) Safe Harbor Policy to further encourage self-disclosures and provide companies with additional predictability in the...more

Goodwin

DOJ Announces Safe Harbor Policy for M&A Self-Disclosures

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On October 4, 2023, the United States Department of Justice (DOJ) announced a “safe harbor” policy for companies that voluntary self-disclose violations identified during the M&A process. US Deputy Attorney General Lisa...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Compelled Interviews Admissible in Criminal Prosecution Against Former Company President and Its General Counsel

A New Jersey federal court has ruled that a company’s self-disclosure of potential Foreign Corrupt Practices Act (FCPA) violations did not render the company a state actor, allowing evidence obtained by its internal...more

Venable LLP

Honesty is Good for Your Bottom Line: Commerce, Treasury, and DOJ Tout the Benefits of Voluntary Self Disclosure in Tri-Seal...

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Voluntary self-disclosure is a valuable remediation measure for companies who identify their own potential violations of U.S. sanctions, export controls, and other national security laws....more

Carlton Fields

Catching More Flies With Honey: Recent DOJ Policy Changes to Coax Cooperation From Corporate Defendants

Carlton Fields on

In March 2023, the Department of Justice announced two policy changes that attempt to incentivize self-disclosure to the federal government and self-imposed remedial measures by corporations charged with criminal wrongdoing....more

Cranfill Sumner LLP

DOJ Announces Sweeping Voluntary Corporate Self-Disclosure Policy

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In late February, the United States Attorneys for the Southern and Eastern Districts of New York announced a new “Voluntary Self-Disclosure Policy” (VSD Policy), effective immediately, that applies to all United States...more

BakerHostetler

DOJ Announces Major Corporate Enforcement Policies

BakerHostetler on

Monaco’s and Polite’s remarks, and the DOJ’s new policies and guidance, come amid the Department’s increasingly tough on corporate crime approach and emphasis on rewarding companies that have effective compliance programs...more

Beveridge & Diamond PC

DOJ Implements Nationwide “Voluntary Self-Disclosure” Program: All U.S. Attorneys’ Offices Instructed to Follow Updated Corporate...

The U.S. Department of Justice (DOJ) formally implemented a nationwide Voluntary Self-Disclosure policy (VSD policy) on February 22, 2023—effective immediately—that has been in the works for several years. The VSD policy...more

Jenner & Block

Client Alert: DOJ Expands the Reach of Its Policies on Self-Disclosure of Corporate Misconduct

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On February 22, 2023, the Department of Justice announced a new Voluntary Self-Disclosure Policy (the Disclosure Policy) that now governs corporate prosecutions by US Attorney’s Offices (USAOs) nationwide. Building on a 2022...more

BakerHostetler

DOJ's Newly Revised Corporate Enforcement Policy Incentivizes Robust Compliance Programs, Cooperation and Remediation

BakerHostetler on

On Jan. 17, AAG Polite announced “the first significant changes” to the CEP since 2017. The policy revisions will apply to all corporate criminal matters handled by the Criminal Division and offer companies “new, significant,...more

Eversheds Sutherland (US) LLP

DOJ sweetens the deal for companies that “come forward, cooperate, and remediate”

On January 17, 2023, Assistant Attorney General Kenneth A. Polite, Jr. (AAG Polite) announced changes to the Department of Justice’s (DOJ) FCPA Corporate Enforcement Policy (CEP). The CEP, which applies to all Criminal...more

Holland & Knight LLP

DOJ Makes Significant Revisions to Corporate Enforcement Policy

Holland & Knight LLP on

The U.S. Department of Justice (DOJ), through Assistant Attorney General Kenneth A. Polite Jr., announced on Jan. 17, 2023, "the first significant changes" to its Corporate Enforcement Policy (CEP) since 2017. The revisions...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Justice Department Memo Raises the Stakes for Workplace Safety–Related Investigations

On September 9, 2015, then U.S. Deputy Attorney General Sally Quillian Yates issued a memo, “Individual Accountability for Corporate Wrongdoing,” that sent shivers down the spines of those in the workplace safety community....more

Goodwin

U.S. Attorney's Office Settles False Claims Act Allegations with Paycheck Protection Program Lender

Goodwin on

On September 13, 2022, the U.S. Attorney’s Office (USAO) for the Southern District of Texas announced ​that it had reached a settlement with a bank that served as a lender under the Paycheck Protection Program (PPP) to...more

NAVEX

The Justice Department’s New Emphasis on a Culture of Compliance

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The week of September 12 was an important one for corporate compliance professionals. We saw two high-ranking officials at the U.S. Justice Department give back-to-back speeches outlining ambitious plans to transform the...more

WilmerHale

The Corporate Crime Advisory Group Has Spoken: DOJ Revises Corporate Criminal Enforcement Policies

WilmerHale on

On September 15, 2022, the Department of Justice (Department) released a memorandum revising several key aspects of its corporate criminal enforcement policies. The new policy, titled Further Revisions to Corporate Criminal...more

McDermott Will & Emery

DOJ Revamps Corporate Criminal Enforcement Policies with Continued Emphasis on Compliance

McDermott Will & Emery on

At a September 15, 2022, speech at New York University School of Law, US Deputy Attorney General (Deputy AG) Lisa Monaco announced several new policies intended to further the aggressive stance the US Department of Justice...more

Paul Hastings LLP

[Webinar] Recent Trends in the U.S. Department of Justice’s International Criminal Investigations - September 8th, 9:00 am - 10:00...

Paul Hastings LLP on

Discussion with two former senior prosecutors on how to handle cases involving Japanese multinational corporations - It is not unusual for the U.S. Department of Justice to investigate non-U.S. multinational corporations...more

Husch Blackwell LLP

The Justice Insiders Podcast: The DOJ Wants You! - Part II: Voluntary Disclosures

Husch Blackwell LLP on

In part two of our series about cooperation and the Department of Justice’s use of its coercive and persuasive powers to conscript an army for DOJ’s corporate enforcement efforts, host Gregg Sofer is joined by Rudy Rivera,...more

Baker Donelson

Two Recent Corporate Pleas Affirm DOJ's Pledge to Crack Down on Criminal Enforcement

Baker Donelson on

Two recent criminal resolutions by the U.S. Department of Justice (DOJ) signal that DOJ is following through on Deputy Attorney General Lisa Monaco's recent pledge to crack down on corporate criminal enforcement....more

Latham & Watkins LLP

DOJ Announces Policy Changes to “Invigorate” Efforts to Combat Corporate Crime - Japanese Version

Latham & Watkins LLP on

今回の米国司法省の政策変更において、司法省は個人の責任に一層の重点を置き、また企業の過去の違法行為に対しては包括的な評価を行い、さらに企業との司法解決に対してはより厳格な対応をすることとなる - 2021年10月28日、米国司法省 (United States Department of Justice、以下「DOJ」)...more

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