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BakerHostetler

DOJ to Corporations - “Knock on Our Door Before We Knock on Yours”

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At last week’s ABA National White Collar Crime Institute, the leadership of the Department of Justice (the DOJ or the Department), including Attorney General Merrick Garland and Deputy Attorney General Lisa Monaco, made clear...more

WilmerHale

DOJ Announces Pilot Whistleblower Rewards Program and Increased AI Enforcement

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On March 7, 2024, Deputy Attorney General Lisa Monaco announced Department of Justice (DOJ) initiatives to incentivize whistleblowers with payouts from civil or criminal forfeitures and to integrate artificial intelligence...more

Bracewell LLP

DOJ Issues New Policy Encouraging Self-Reporting FCPA Violations

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On November 29, 2017 the Deputy Attorney General of the U.S. Department of Justice (DOJ), Rod J. Rosenstein, announced a new FCPA enforcement policy that seeks to incentivize voluntary self-reporting by providing companies...more

Bradley Arant Boult Cummings LLP

DOJ’s FCPA Corporate Enforcement Policy Creates Greater Certainty for Companies

The Foreign Corrupt Practices Act of 1977 (FCPA) makes it unlawful for certain classes of persons and entities to make payments to foreign government officials to assist in obtaining or retaining business. On November 29,...more

Jones Day

DOJ's New FCPA Enforcement Policy Continues its "Carrot-and-Stick" Approach

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The Situation: Companies that learn of Foreign Corrupt Practices Act ("FCPA") violations by employees or agents are faced with significant uncertainty as to whether the benefits and risks of self-disclosing the conduct to the...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Announces Revised FCPA Corporate Enforcement Policy

In a speech yesterday at the 34th International Conference on the Foreign Corrupt Practices Act, U.S. Deputy Attorney General Rod Rosenstein announced the Department of Justice’s (DOJ) revised Foreign Corrupt Practices Act...more

Ruder Ware

Sally Yates’ was Already Famous for Changing the Focus of Compliance Investigations - The Yates Memorandum

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By now the whole world knows about Sally Yates. We are likely to see a lot more of her as a central figure in Congressional investigations. For some of us who deal with compliance investigations, Sally Yates was famous long...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2016 Developments and Predictions for 2017

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The past year was consequential for FCPA enforcement in numerous respects, including blockbuster penalties, new policy initiatives, and the SEC’s first DPA with an individual for FCPA violations. In April 2016, the DOJ’s...more

Thomas Fox - Compliance Evangelist

JPMorgan Sons and Daughters FCPA Enforcement Action, Part III-St. Mark’s Revealed

This week I am exploring the JP Morgan Chase (JPM) and its subsidiary, JPMorgan Securities (Asia Pacific) Limited (JPM-APAC), (collectively ‘the company’) Foreign Corrupt Practices Act (FCPA) enforcement action which...more

Thomas Fox - Compliance Evangelist

Compliance isn’t Going Away (and Neither Should You) – Part III

I continue what has now become a week-long explanation of why the compliance function in a corporation and the compliance profession in general is not going anywhere, even with the election of Trump as President and a full...more

Thomas Fox - Compliance Evangelist

Hallmark 5-Communications and Training

I. Training - The communication of your anti-corruption compliance program is something that must be done on a regular basis to ensure its effectiveness. The FCPA Guidance explains, “Compliance policies cannot work...more

Carlton Fields

DOJ’s FCPA Pilot Program Keeps Heat on Individuals

Carlton Fields on

In April, the Department of Justice (DOJ) announced a one-year pilot program offering certain violators of the Foreign Corrupt Practices Act (FCPA) the possibility of reduced sanctions on top of any credit provided for by the...more

The Volkov Law Group

White Collar Criminal Sentencing – What A Difference Cooperation Makes

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The political campaign season has included plenty of discussion surrounding reforming our criminal justice system, and in particular sentencing for drug offenses. We have not heard much discussion about white-collar criminal...more

Dorsey & Whitney LLP

Dorsey Anti-Corruption Digest - April 2016

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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

NAVEX

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

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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

Dechert LLP

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

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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

Skadden, Arps, Slate, Meagher & Flom LLP

"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

Alston & Bird

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

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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

Thomas Fox - Compliance Evangelist

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

Pillsbury Winthrop Shaw Pittman LLP

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

Thomas Fox - Compliance Evangelist

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

Clark Hill PLC

DOJ's New FCPA Guidance and Pilot Program

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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

BakerHostetler

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

BakerHostetler on

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

Bracewell LLP

DOJ Launches FCPA Pilot Program to Promote Company Self-Reporting

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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

Miller Canfield

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

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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

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