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Enforcement Guidance Compliance

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

Beltway Buzz - May 2024

The Beltway Buzz is a weekly update summarizing labor and employment news from inside the Beltway and clarifying how what’s happening in Washington, D.C., could impact your business....more

The Volkov Law Group

Justice Department Focuses on Artificial Intelligence Assisted Crime

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In the face of rapid technology changes, the Department of Justice usually has to play catch up.  When cryptocurrency and blockchain entered the United States economy, the Justice Department played catch up.  Fraudsters and...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2023 Developments and Predictions for 2024

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Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more

Thomas Fox - Compliance Evangelist

The DOJ on the Need for Compliance Program Data Analytics

The Department of Justice (DOJ) is increasingly utilizing data analytics for proactive enforcement, signaling a significant shift in their approach to combating white-collar crime. This move reflects the recognition of data...more

WilmerHale

Breaking With Precedent - New Guidance on Future CFTC Enforcement Resolutions

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The Commodity Futures Trading Commission (CFTC) Division of Enforcement recently released a new advisory to its staff related to penalties, corporate compliance monitors and consultants, and admissions in CFTC enforcement...more

Goodwin

Antitrust & Competition Healthcare Quarterly Update - Q1 2023

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Department of Justice Withdraws Long-Standing Antitrust Healthcare Policy Statements - On February 2, 2023, the Antitrust Division of the US Department of Justice (DOJ) announced the withdrawal of its support for three...more

The Volkov Law Group

DOJ’s Enforcement and Compliance Changes: Weighing the Pros and Cons of Voluntary Disclosures

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The Justice Department certainly has altered the landscape of enforcement, compliance priorities, and ultimately corporate decisions surrounding voluntary disclosure.  It has become a little bit more complicated to sort out...more

The Volkov Law Group

A Five Step Program for Every Company to Address the New Enforcement Threats

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Companies have to demand a new focus from their CEOs, senior executives and legal compliance team in response to the new DOJ and regulatory initiatives.  These steps are not just suggestions nor items that can be prioritized...more

The Volkov Law Group

Corsa Coal Earns Declination and Agreed to Disgorge $1.2 Million

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The Justice Department has been pushing its voluntary self-disclosure program and changes to its Corporate Enforcement Policy, in an attempt to increase FCPA enforcement cooperation.  The Golden Ring for every company facing...more

Miles & Stockbridge P.C.

Forewarned is Forearmed: DOJ’s Corporate Voluntary Self-Disclosure Policy

The U.S. Department of Justice (DOJ) on Wednesday issued a new Voluntary Self-Disclosure (VSD) Policy for United States Attorney’s Offices, effective immediately. “The policy details circumstances under which a company will...more

Hogan Lovells

DOJ sets forth new incentives for companies to self-disclose and cooperate

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On January 17, 2023, the Department of Justice (DOJ) rolled out revisions to its Corporate Enforcement Policy (CEP) aimed at incentivizing companies to voluntarily self-disclose misconduct and to cooperate with government...more

The Volkov Law Group

DOJ Promoting Enforcement and Compliance Message

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Contrary to the often-repeated narrative, the Justice Department is transparent about its enforcement plans and compliance expectations.  Since the issuance of the FCPA Guidance in 2012, DOJ has continued to provide guidance...more

The Volkov Law Group

ABB – A Three-Time Loser – Settles FCPA Case for Bribery in South Africa for $315 Million (Part I of III)

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The Justice Department’s new Corporate Enforcement Policy and the heightened enforcement and compliance expectations were put to the test in its announcement of a $315 million settlement of bribery charges with ABB, a...more

Skadden, Arps, Slate, Meagher & Flom LLP

Enforcement Authorities Urge Integration of Corporate Compliance Programs in 2023

The fundamental components of effective corporate compliance programs have not changed significantly in recent years. However, United States enforcement authorities are trying to reinvigorate companies’ attention to those...more

The Volkov Law Group

Voluntary Self-Disclosure — DOJ’s Enforcement Engine

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The Department of Justice and many regulatory agencies have rolled out the red carpet for companies to cross the threshold and voluntarily disclose criminal conduct in the hopes of gaining leniency, immunity and reduced fines...more

Venable LLP

Part 1: Cooperation in Government Investigations and Voluntary Self-Disclosure: What to Expect After DOJ’s Latest Guidance

Venable LLP on

​​​​​​​On September 15, Deputy Attorney General Lisa Monaco issued a department-wide memorandum containing revisions to the Justice Department’s (DOJ) corporate criminal enforcement policies (“the Memorandum”), including...more

The Volkov Law Group

Commerce Department Tacks to New Aggressive Enforcement Program

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The Commerce Department’s Bureau of Industry and Security (“BIS”) has decided to join the enforcement club.  BIS’s recent announcement of new policies to administrative actions should not be surprising.  ...more

BakerHostetler

Understanding and Complying with the Uyghur Forced Labor Protection Act

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The Uyghur Forced Labor Protection Act (UFLPA) applies to all merchandise imported into the United States on or after June 22, 2022. The UFLPA establishes a rebuttable presumption that goods mined, produced, or manufactured...more

The Volkov Law Group

The United States Strategy on Countering Corruption: Digging into the Anti-Corruption Initiatives (Part III of III)

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The new United States Strategy on Countering Corruption includes several important statements of interest to legal and compliance professionals.  ...more

BCLP

Observations from a Review of FINRA’s 2021 Sanction Guidelines

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Key Takeaways: ..FINRA released its most recent Sanctions Guideline, effective immediately, on October 20, 2021. A link to that document can be found here. ..The key change in the 2021 Sanctions Guideline is a new...more

WilmerHale

A Look Ahead into Corporate Enforcement in the Biden Administration

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Just one year after President Biden’s election, senior administration officials have signaled in public remarks that the federal government will amplify enforcement pressure on corporations and their employees through...more

Bracewell LLP

DOJ's Torpedoes Are in the Water: Be Your Own Monitor, or One will Be Appointed for You

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Last week, at a gathering of the nation’s top white collar criminal defense attorneys in Miami, Florida, Deputy Attorney General Lisa Monaco announced material changes to the way the Department of Justice will investigate,...more

The Volkov Law Group

Environmental Crime Enforcement: Button Up for an Increase in Criminal Investigations and Compliance Demands

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The Biden Administration has a number of enforcement priorities.  While not listed as a primary objective, the Justice Department and the EPA can be expected to increase criminal enforcement of environmental laws....more

Holland & Knight LLP

Paycheck Protection Program Loan Forgiveness: Mandatory OSHA Compliance

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Employers are potentially eligible for a new round of Paycheck Protection Program (PPP) loans through the U.S. Small Business Administration (SBA). The SBA PPP loan application requires borrowers to certify that they are, to...more

The Volkov Law Group

The Coming AML Enforcement Storm

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Blog after blog, commentator after commentator, and everyone else who has an opinion has been repeating the same message – the Biden Administration is going to increase enforcement risks....more

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