Federal Pilot Programs

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DOJ’s New FCPA “Pilot Program” Targets Corporate Officers and Other Individuals

For years, FCPA observers have predicted that the Department of Justice (“DOJ”) will increase its prosecutions of corporate officers and employees for FCPA violations. These predictions have so far proven disputable, as the...more

Red Notice Newsletter - April 2016

ANTICORRUPTION DEVELOPMENTS – Final Judgments Entered Against Seven Former DAP Employees; Four Ordered to Pay - The Securities and Exchange Commission (SEC) announced earlier this month that on April 6 and 7, 2016,...more

To Self-Report or Not to Self-Report, That Remains the Question After the Justice Department’s Latest Effort to Encourage...

On April 5, 2016, the United States Department of Justice, Criminal Division, Fraud Section launched a one-year Pilot Program that invites companies to self-report potential violations of the Foreign Corrupt Practices Act...more

Dorsey Anti-Corruption Digest - April 2016

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more

Is the DOJ’s New FCPA Pilot Program an Offer You Can’t Refuse?

Earlier this month, Assistant US Attorney Leslie Caldwell announced that the US Department of Justice’s Criminal Division Fraud Section will try to entice companies to self-report potential FCPA issues. The DOJ included...more

A transatlantic consideration of recent developments in corporate self-reporting

More carrot, less stick? On 5 April 2016, the Fraud Section of the US Department of Justice’s (DOJ) Criminal Division issued an Enforcement Plan and Guidance (the DOJ Guidance), setting out the steps that it is taking to...more

Federal FCPA Pilot Program Encourages Self-Disclosure and Cooperation

“Voluntary self-disclosure of criminality,” “full cooperation” and “timely and appropriate remediation” in connection with violations of the Foreign Corrupt Practices Act (FCPA) are the main ingredients in the recipe for...more

DOJ Announces FCPA Pilot Program in an Effort to Incentivize Companies to Self-Report Misconduct

Action Item: On April 5, 2016, the U.S. Department of Justice (“DOJ”) issued a memorandum laying out a one-year pilot program designed to offer mitigation credit to companies that voluntarily disclose Foreign Corrupt...more

Pilot Program May Soon Help Streamline Employment-based Visa Process

On March 3, 2016, the U.S. Department of Homeland Security (DHS) launched a pilot program called “Known Employer” to streamline the process by which employers who sponsor foreign national workers send documents and...more

DOJ Criminal Division Launches One-Year Pilot Program as Part of Enhanced FCPA Enforcement Strategy

On April 5, 2016, the Department of Justice (“DOJ”) Criminal Division’s Fraud Section released a memorandum setting out “three steps” in its “enhanced” enforcement of the Foreign Corrupt Practices Act (“FCPA”). See Apr. 5,...more

New US Department of Justice Foreign Corrupt Practices Act Enforcement Plan Creates "Pilot Program" to Encourage Voluntary...

The U.S. Department of Justice (“DOJ”) released a memorandum (the “FCPA Enforcement Memorandum”) on April 5, 2016 detailing a new enforcement plan for Foreign Corrupt Practices Act (“FCPA”) investigations. The DOJ announced...more

The Race to Regulate Autonomous Vehicles is On

While the potential benefits of automated vehicles are receiving well-deserved attention, there is significant uncertainty as to what the regulatory framework will look like for this exciting technology — particularly from an...more

"DOJ Adds Resources for FCPA Cases, Offers Incentives for Voluntary Disclosures"

On April 5, 2016, the Department of Justice’s (DOJ) Fraud Section made two related announcements in its Foreign Corrupt Practices Act (FCPA) Enforcement Plan and Guidance. First, the Fraud Section announced a substantial...more

DOJ Announces FCPA Enforcement Pilot Program

The U.S. Department of Justice (DOJ) recently announced a one-year enforcement pilot program intended to encourage companies to voluntarily self-report misconduct under the Foreign Corrupt Practices Act (FCPA). Building on...more

Government & Internal Investigations Advisory: DOJ’s New FCPA Pilot Program Provides Roadmap for “Cooperation”

The Department of Justice (DOJ) on April 5 announced a new, one-year pilot program for companies to self-report Foreign Corrupt Practices Act (FCPA) violations. The announcement comes amid other increased FCPA enforcement...more

New DOJ Guidance and FCPA Pilot Program – Part IV: Impact

This week I have been exploring the implications of the Department of Justice (DOJ) announcement last week of a new program Pilot Program around Foreign Corrupt Practices Act (FPCA) enforcement, together with the document,...more

New FCPA Self-Reporting Pilot Program Formalizes Rewards but Relies on Discretionary Implementation

On April 5, 2016, the Department of Justice unveiled a one-year pilot program designed to encourage companies to self-report violations of the Foreign Corrupt Practices Act (the FCPA). Built upon the Department’s September 9,...more

New DOJ Guidance and FCPA Pilot Program – Part III: Ongoing Remediation

I continue my exploration of the implications from the Department of Justice (DOJ) announcement last week of a new program around Foreign Corrupt Practices Act (FPCA) enforcement, the “Pilot Program”. Contemporaneously, the...more

DOJ's New FCPA Guidance and Pilot Program

On April 5, 2016, in an effort to bolster FCPA Compliance, the Department of Justice issued its "Foreign Corrupt Practices Act Enforcement Plan and Guidance" identifying the following three steps to enhance its FCPA...more

DOJ Attempts to Encourage Corporate Self-Disclosures With the Announcement of a One-Year FCPA Pilot Program

Pursuing a classic “carrot and stick” approach to incentivizing corporate self-disclosure of FCPA violations and individual wrongdoing connected to FCPA violations, the Department of Justice (DOJ) Fraud Section announced a...more

DOJ Announces New Pilot Program to Encourage FCPA Cooperation and Self-Reporting

On April 5, the DOJ announced a one-year pilot program designed to encourage corporations to voluntarily self-report FCPA-related misconduct and cooperate with the DOJ. The program emerges from the DOJ’s heightened focus on...more

DOJ Launches FCPA Pilot Program to Promote Company Self-Reporting

In a speech delivered last Wednesday by Assistant Attorney General Leslie Caldwell, the Justice Department’s (“DOJ”) Criminal Division announced the launch of a new Foreign Corrupt Practices Act (“FCPA”) “pilot program” that...more

New DOJ Guidance and FCPA Pilot Program – Part II: Cooperation

Today, I continue my exploration of the implications from the Department of Justice (DOJ) announcement last week of a new program around Foreign Corrupt Practices Act (FPCA) enforcement (herein “Pilot Program”)....more

DOJ’s Fraud Section Issues Foreign Corrupt Practices Act Enforcement Plan and Guidance

On April 5, 2016, the Department of Justice’s Fraud Section (“DOJ”) issued its Foreign Corrupt Practices Act (“FCPA”) Enforcement Plan and Guidance (“Guidance”), which announced (1) a more than doubling of DOJ resources...more

DOJ's New FCPA Pilot Program Will Have Only Marginal Impact

On April 5, 2016, Assistant Attorney General Leslie Caldwell, who heads the Criminal Division of the U.S. Department of Justice, announced a new “FCPA pilot program” designed to motivate companies to voluntarily self-disclose...more

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