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Criminal Prosecution Department of Justice (DOJ) White Collar Crimes

Thomas Fox - Compliance Evangelist

Lessons on Ongoing Monitoring and Continuous Improvement from Star Trek: Spectre of the Gun

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

The Volkov Law Group

DOJ Implements New Corporate Whistleblower Plan to Accelerate Corporate Criminal Enforcement (Part I of II)

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DOJ is feeling the heat.  Corporate criminal enforcement numbers are down. in fairness, DOJ has been pushing individual criminal enforcement as an effective deterrent to corporate misconduct.  Criminal prosecutions, when done...more

The Volkov Law Group

Episode 333 -- The Boeing Proposed Plea Agreement

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The Boeing 737 MAX case took another dramatic turn.  On July 24, 2024, the Department of Justice filed with the United States District Court for the Northern District of Texas a proposed plea agreement with Boeing.  The plea...more

A&O Shearman

DOJ Kicks Off Whistleblower Rewards Program

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On August 1, 2024, the Department of Justice issued guidance outlining its Corporate Whistleblower Awards Pilot Program, which offers financial incentives to whistleblowers who bring original and truthful information...more

The Volkov Law Group

Deep Dive into Proposed Boeing Plea Agreement (Part II of III)

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DOJ and Boeing have entered into a proposed plea agreement that will require judicial scrutiny and determinations of the public interest and the victims’ rights under the Crime Victims’ Rights Act, 18 U.S.C. § 3771 [“CVRA”]. ...more

Epstein Becker & Green

DOJ Criminal Fraud Section’s Annual Health Care Fraud Enforcement Action: “We Are a Target-Rich Environment”

On June 27, 2024, the U.S. Department of Justice (“DOJ”) and the U.S. Department of Health and Human Services, Office of Inspector General (“HHS-OIG”), along with other federal and state law enforcement partners, announced...more

Thomas Fox - Compliance Evangelist

The DOJ Boeing Conundrum

The Department of Justice (DOJ) is currently in a conundrum over its Deferred Prosecution Agreement (DPA) for the Boeing 737 Max crashes. Understanding the implications of the DOJ’s upcoming decision on whether to prosecute...more

Wilson Sonsini Goodrich & Rosati

National Security Division’s Voluntary Self-Disclosure Policy in Action: Exchanging Cooperation for Declination

Last month, the U.S. Department of Justice (DOJ) announced that it would not charge MilliporeSigma, a life sciences company, even though one of its employees falsified export documents. The DOJ declined to prosecute...more

The Volkov Law Group

Episode 324 -- Third-Party Risks and Sanctions Compliance

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With the beginning of the “New FCPA” era coined by DOJ’s Deputy Attorney General Lisa Monaco, we now need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important and not just...more

Jenner & Block

DOJ Announces New Whistleblower Rewards Program and Enhanced Focus on AI-Related Risks

Jenner & Block on

The Department of Justice (DOJ) recently announced two new measures to enhance its corporate criminal enforcement efforts: a whistleblower rewards program and updated guidance under which federal prosecutors will assess risks...more

Bradley Arant Boult Cummings LLP

Criminal Division’s new voluntary self-disclosure program still uncertain and risky

On April 15, 2024, the Department of Justice released its “Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals.” Similar in many ways to programs introduced earlier this year by the U.S. Attorney’s...more

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

DOJ Launches New Pilot Program to Allow Whistleblowers Who Report Financial Crimes, Corruption to Avoid Prosecution

On April 15, 2024, the U.S. Department of Justice (DOJ) Criminal Division launched a new pilot program to enable whistleblowers to avoid prosecution when they voluntarily report new information to federal law enforcement...more

Polsinelli

"Please Pay No Attention to the Microphone:” DOJ Announces New Program Offering Protections to Criminal Whistleblowers

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On April 15, 2024, the Criminal Division of the U.S. Department of Justice (“DOJ”) released new guidance relating to a Pilot Program on Voluntary Self-Disclosures for Individuals, promising to offer protection from criminal...more

Jones Day

DOJ Criminal Division Offers Non-Prosecution Agreements to Individuals Who Voluntarily Report Corporate Wrongdoing

Jones Day on

The Development: On April 15, 2024, the Department of Justice ("DOJ") Criminal Division announced a pilot program that will offer mandatory non-prosecution agreements ("NPAs") to individuals who provide original and...more

Perkins Coie

DOJ Pilot Program Changes the Calculus on Corporate Self-Disclosure

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The Criminal Division of the U.S. Department of Justice (DOJ) announced a Pilot Program on Voluntary Self-Disclosures for Individuals (Pilot Program) on April 15, 2024. Under the new policy, individuals who were involved in...more

Epstein Becker & Green

The Department of Justice’s Criminal Division Launches a Pilot Program on Voluntary Self-Disclosures for Individuals

Epstein Becker & Green on

Since October 2021, the Department of Justice (DOJ) has been implementing a variety of changes to its corporate criminal enforcement policies. These efforts all reflect DOJ’s focus on individual accountability, punishing...more

Woods Rogers

EPA’s Landmark Civil-Criminal Enforcement Policy (Part I)

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Last week, the EPA announced a landmark policy change regarding the intersection and overlap of criminal and civil investigations/enforcement actions. EPA’s new policy represents one of the most dramatic and important changes...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Pilot Program Promises Non-Prosecution Agreements to Individuals Reporting Fraud, Bribery and Other Corporate Crimes

On April 15, 2024, the Department of Justice’s (DOJ’s) Criminal Division unveiled a new Pilot Program on Voluntary Self-Disclosures for Individuals that offers non-prosecution agreements (NPAs) to individuals who voluntarily...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the...

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In a single decade, the prosecutions of those accused of white-collar crime underwent a radical transformation. This thought-provoking episode will take you back in time to explore the DOJ's approach in the early 2000s Enron...more

Nelson Mullins Riley & Scarborough LLP

Bringing Moths to the Flame: DOJ Promises Non-Prosecution to Execs for Tips to Combat Corporate Crime

Recently, the Department of Justice (DOJ) Criminal Division launched a pilot program promising “mandatory NPAs to incentivize individuals (and their counsel) to provide original and actionable information.” This most recent...more

Alston & Bird

The Race is On: DOJ's Criminal Division the Latest to Offer Non-Prosecution Deals to Whistleblowers

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Our White Collar, Government & Internal Investigations Group investigates the latest federal whistleblower program, which offers individuals yet another avenue to report corporate misconduct....more

Bradley Arant Boult Cummings LLP

DOJ Takes the Next Step in Its Effort to Increase Voluntary Self-Disclosures By Incentivizing Those Complicit in Wrongdoing

On April 15, the U.S. Department of Justice released The Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals (the “Pilot”) designed to encourage individuals to report certain types of criminal...more

Bradley Arant Boult Cummings LLP

“Take Me to the Pilot” – DOJ Announces Plan to Entice Self-Disclosures of Government Contract Fraud

On April 15, the U.S. Department of Justice released The Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals (the Pilot) designed to encourage individuals to report certain types of criminal...more

The Volkov Law Group

Lessons-Learned from the Trafigura FCPA Settlement (Part III of III)

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The Justice Department is rightly trumpeting its successful sweep of the commodities trading industry.  DOJ’s success is reflected in its six separate corporate resolutions and 20 individual convictions, resulting in over...more

The Volkov Law Group

Trafigura’s Bribery Scheme: Clandestine Meetings, 3rd Parties and Shell Companies (Part II of III)

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Trafigura’s bribery scheme resembles the same schemes implemented by its significant competitors — Vitol, Glencore, Gunvor.  At the core of the conduct, Petrobras and Brazilian government officials collected bribes in...more

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