News & Analysis as of

Deferred Prosecution Agreements DPA

McDermott Will & Emery

First of Its Kind: Drug Wholesaler Accepts DPA and Two Executives Face Criminal Charges in SDNY For Illegal Distribution of...

On April 23, 2019, the US Department of Justice (DOJ) announced it has entered into a deferred prosecution agreement with Rochester Drug Co-Operative, Inc. (RDC), one of the 10 largest wholesale distributors of pharmaceutical...more

BakerHostetler

Foreign Corrupt Practices Act 2015 Update

BakerHostetler on

Despite a decline in enforcement actions by the Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), the first half of 2015 has continued to highlight the relevance and ever-evolving effects of the...more

Thomas Fox - Compliance Evangelist

The Defeat Device: Compliance and Ethics in the Auto Industry

Things are seriously bad when one of the world’s most respected business focused publications, the Financial Times (FT), asks if the auto “industry faces ‘Libor moment’”? Yet that was a headline yesterday in the lead article...more

Troutman Pepper

Executives Beware: The DOJ and SEC Have Set Their Sights on Individual Wrongdoing

Troutman Pepper on

The DOJ’s Yates Memo makes individual prosecutions a higher priority and makes a company’s own identification of potentially culpable individuals an explicit factor in assessing cooperation credit....more

The Volkov Law Group

The True Impact of DOJ’s Individual Prosecution Memo

The Volkov Law Group on

The Justice Department can surprise you – the release of the Yates Memo, as it is commonly referred to since it takes on the name of the Deputy Attorney General (e.g. McNulty Memo), is another strange example of DOJ...more

Cadwalader, Wickersham & Taft LLP

New DOJ Policy Regarding Individual Accountability for Corporate Wrongdoing

On September 9, 2015, the U.S. Department of Justice announced a new policy regarding individual accountability for corporate misconduct. The policy, described in a memo authored by Deputy Attorney General Sally Yates,...more

Ballard Spahr LLP

D.C. Circuit to Decide Scope of Judges’ Authority in Approval Process for Deferred Prosecution Agreements

Ballard Spahr LLP on

A federal judge exceeded his authority when he rejected a deferred prosecution agreement (DPA) entered into earlier this year by the U.S. Department of Justice (DOJ) and a Dutch aerospace company, the DOJ and company will...more

Thomas Fox - Compliance Evangelist

Social Media Week Part VI – Social Media and CCO 3.0

I conclude this exploration of the uses of social media in doing compliance by exploring why the compliance function is uniquely suited to using social media tools. Long gone are the days when Chief Compliance Officers (CCO)...more

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