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Seward & Kissel LLP

DOL Finalizes Amendments to the QPAM Exemption – All QPAMs Must Take Action

Seward & Kissel LLP on

On April 3, 2024, the U.S. Department of Labor (DOL) published significant modifications to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption). The amendment becomes effective on June 17, 2024; however, certain...more

Paul Hastings LLP

More Clarity on the Horizon for FCPA Resolutions? DOJ and SEC Officials Discuss Enforcement Trends

Paul Hastings LLP on

On November 28–30, 2023, the American Conference Institute’s 40th International Conference on the Foreign Corrupt Practices Act (“FCPA”), held in Washington, D.C., brought together prosecutors, regulators, corporate...more

HaystackID

Cooperation Standards in Government Investigations: Practical Tips

HaystackID on

Editor’s Note: From time to time, ComplexDiscovery highlights publicly available or privately purchasable announcements, content updates, and research from cyber, data, and legal discovery providers, research organizations,...more

BakerHostetler

DOJ Corporate Compliance Certifications Appear to Be Here to Stay

BakerHostetler on

The compliance certification policy was first announced by Assistant Attorney General (Assistant AG) Kenneth Polite in March 2022, when he stated that for all criminal division “corporate resolutions (including guilty pleas,...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

Latham & Watkins LLP

The International Investigations Review, 12th Edition - England & Wales

Latham & Watkins LLP on

In its second year, the Biden administration has made clear its prioritisation of white-collar prosecutions. This includes changes in policy and guidance, such as a renewed focus on individual accountability, an increased...more

American Conference Institute (ACI)

DOJ CCO Certification Requirement Will Up the Ante of CCO Oversight

Officials with the U.S. Department of Justice have portended a sea change in the oversight responsibilities of chief compliance officers (CCOs) as it concerns corporate resolutions going forward. In public remarks made March...more

Society of Corporate Compliance and Ethics...

Federal Monitorships and Making Them Work

For a time monitorships were, if not endangered, out of favor. After many years of embracing them, the US Department of Justice had begun calling for cost benefit analyses and looking for alternatives. Then in 2021 Deputy...more

Torres Trade Law, PLLC

There’s A New Compliance Sheriff In Town, And She’s Cracking Down On Corporate Misconduct

Torres Trade Law, PLLC on

The U.S. Department of Justice ("DOJ") is making it harder on companies that commit corporate crimes. A lot harder. That’s the message that Deputy Attorney General Lisa Monaco recently gave attendees at the American Bar...more

Thomas Fox - Compliance Evangelist

Not Your Father’s Monitor – Bethany Hengsbach on White Collar Enforcement and Defense

In October, Deputy Attorney General (DAG) Lisa O. Monaco gave a Keynote Address at ABA’s 36th National Institute on White Collar Crime (Monaco Speech). Her remarks reframed a discussion about the uses of, reasons for and...more

Vinson & Elkins LLP

Why Voluntary Independent Compliance Monitorships Are Growing in Popularity

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When companies get into trouble, it’s common practice for the government to call on independent third parties to help clean up the mess. Companies under investigation by the Department of Justice (“DOJ”) often agree to...more

Holland & Hart LLP

DOJ Announces Significant Changes to Corporate Criminal Enforcement Policies

Holland & Hart LLP on

On October 28, 2021, Deputy Attorney General Lisa Monaco issued a Memorandum entitled “Corporate Crime Advisory Group and Initial Revisions to Corporate Criminal Enforcement Policies,” which she explained the same day in her...more

Latham & Watkins LLP

Senior US DOJ Official Sets Forth New Priorities for Pursuing Corporate Crime

Latham & Watkins LLP on

The priorities will impact non-US companies who may face a US DOJ with a renewed emphasis on combating corporate crime. In a recent speech that has garnered significant attention, the Deputy Attorney General of the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Practical Steps To Address DOJ Changes to Corporate Enforcement Policies

In one of the first substantive speeches on corporate criminal enforcement under the Biden administration, Deputy Attorney General Lisa Monaco announced on October 28, 2021, several immediate changes to Department of Justice...more

The Volkov Law Group

Here Comes DOJ – Corporate Crime Enforcement

The Volkov Law Group on

Lisa Monaco, the Deputy Attorney General (No. 2 in DOJ), delivered an important speech at the National Institute of White Collar Summit.  Lisa was part of the Enron Task Force years ago and has a strong professional...more

Eversheds Sutherland (US) LLP

US Department of Justice adopts “bold” approach to prosecuting corporate crime and will engage in “rigorous enforcement”

On October 28, 2021, Deputy Attorney General (Deputy AG) Lisa O. Monaco gave remarks explicitly warning companies that the US Department of Justice (DOJ) intends to increase its efforts and devote additional resources to...more

Latham & Watkins LLP

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

Latham & Watkins LLP on

The changes include more focus on individual accountability, more holistic evaluation of prior corporate misconduct, and stricter corporate resolutions. On October 28, 2021, US Deputy Attorney General Lisa Monaco gave the...more

Morrison & Foerster LLP

Deputy Attorney General Lisa Monaco Emphasizes Continued Focus on White Collar Crime Enforcement by the U.S. Department of Justice

The Department of Justice (“DOJ” or “Department”) has continued to make clear that white collar crime is a top priority of its enforcement efforts. On October 28, 2021, Deputy Attorney General (“DAG”) Lisa Monaco issued a...more

Orrick, Herrington & Sutcliffe LLP

DOJ Determined to “Better Combat Corporate Crime”

The Department of Justice under the Biden Administration signaled yesterday that it will be putting more resources towards investigating corporate crime – and expecting more from companies who come under investigation. On...more

Hogan Lovells

DAG Monaco announces shift in DOJ enforcement policies - Prioritizing corporate misconduct and individual accountability

Hogan Lovells on

On October 28, 2021, Deputy Attorney General (DAG) Lisa O. Monaco gave the keynote address at the ABA’s 36th National Institute on White Collar Crime and announced a series of changes in the Department of Justice’s (DOJ)...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Compliance Program Guidance Shows Value of a Compliance Committee

Though directed at prosecutors, the June 1, 2020, guidance on corporate compliance programs (Guidance) from the U.S. Department of Justice (DOJ) is a source of practical advice for in-house legal and compliance teams in...more

Kilpatrick

Ending the Decade on a High: U.S. Government’s 2019 FCPA Enforcement Highlights

Kilpatrick on

The U.S. Government’s 2019 FCPA enforcement efforts led to new milestones; further cooperation with international authorities; and continued use of independent corporate monitors.  The following are key takeaways of these...more

A&O Shearman

FCPA Digest - Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act - July 2019

A&O Shearman on

Recent Trends And Patterns In FCPA Enforcement - Although the DOJ and SEC brought a relatively low number of FCPA enforcement actions in the first half of 2019, an unusually large portion of those enforcement actions...more

Thomas Fox - Compliance Evangelist

TechnipFMC FCPA Enforcement Action: Part 1 – Introduction

Last week closed out one of the most interesting half-years in the Foreign Corrupt Practices Act (FCPA) realm. We have had the Cognizant Technology Solutions Corporation declination, Fresenius Medical Care AG & Co. KGaA...more

K&L Gates LLP

The Benczkowski Memorandum: DOJ’s New Guidance on Corporate Monitors

K&L Gates LLP on

On October 12, 2018, Assistant Attorney General Brian A. Benczkowski announced the publication of a new U.S. Department of Justice (“DOJ”) memorandum regarding the selection of corporate monitors in Criminal Division matters...more

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