News & Analysis as of

Fraud Federal Pilot Programs

Fraud is the making of false representations or engaging in deceptive behavior in order to unlawfully secure financial or personal gain. 
Ogletree, Deakins, Nash, Smoak & Stewart,...

Whistleblower Update: SEC, DOJ Still Focusing on Employment Agreements and Written Policies, Off-Channel Communications

The U.S. Securities and Exchange Commission (SEC) brought more actions targeting regulated entities for recordkeeping violations related to employees using noncompany communications platforms, and both the SEC and the U.S....more

Proskauer Rose LLP

DOJ Triples Down on Incentivizing Disclosures with Launch of Three-Year Corporate Whistleblower Awards Pilot Program

Proskauer Rose LLP on

Corporate Whistleblower Awards Pilot Program (“Pilot Program”), aimed at incentivizing whistleblowers to report potential criminal conduct. The announcement was anticipated, having been previewed in March 2024 by Deputy...more

The Volkov Law Group

DOJ Implements New Corporate Whistleblower Plan to Accelerate Corporate Criminal Enforcement (Part I of II)

The Volkov Law Group on

DOJ is feeling the heat.  Corporate criminal enforcement numbers are down. in fairness, DOJ has been pushing individual criminal enforcement as an effective deterrent to corporate misconduct.  Criminal prosecutions, when done...more

American Conference Institute (ACI)

The DOJ’s New Pilot Programs: A Bane for Compliance Programs

For years, Department of Justice officials have stressed how important chief compliance officers are as the first line of defense in fighting corporate crimes. While that’s true, compliance programs now have a competitor in...more

Foley Hoag LLP - White Collar Law &...

Anticorruption Enforcement and the Foreign Corrupt Practices Act: Trends to Track in 2024

This is the seventh in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more

BakerHostetler

The Lines Are Open! DOJ Adds New Tool in Anticorruption Efforts With Whistleblower Pilot Program

BakerHostetler on

Building on the recent passage of the Foreign Extortion Prevention Act (FEPA), at the American Bar Association’s 2024 National Institute on White Collar Crime conference in San Francisco earlier this month (2024 ABA...more

PilieroMazza PLLC

Weekly Update Newsletter - February 2019 #2

PilieroMazza PLLC on

GOVERNMENT CONTRACTING - The Small Business Administration (SBA) announced a series of workshops geared to help Native American small business communities with technical assistance and business development. The SBA will...more

Dechert LLP

Corporate Compliance Programs: US and UK Perspectives

Dechert LLP on

In today’s regulatory environment, companies face mounting pressure from law enforcement agencies to maintain robust compliance programs to deter and detect misconduct by employees, third-party vendors and business partners....more

Pillsbury Winthrop Shaw Pittman LLP

Great Expectations - DOJ holds anti-corruption compliance programs to a high standard in evaluating their credibility

On February 8, 2017, the U.S. Department of Justice (DOJ) released a list of important topics and sample questions that the Criminal Division’s Fraud Section has frequently found relevant in evaluating the adequacy of a...more

Thomas Fox - Compliance Evangelist

When the Compliance Counsel Speaks, CCOs Should Listen

I was recently having breakfast with a colleague and we were discussing the Department of Justice’s (DOJ) Compliance Counsel Hui Chen and what we believe to be the positive impact she has had on the compliance community,...more

Snell & Wilmer

The Foreign Corrupt Practices Act’s One-Year “Pilot Program” Nears The Halfway Mark

Snell & Wilmer on

The Foreign Corrupt Practices Act (“FCPA”) prohibits both United States and foreign corporations and nationals from offering or paying, or authorizing the offer or payment, of anything of value to a foreign government...more

Seyfarth Shaw LLP

FCPA Compliance---Recent Department of Justice Initiatives

Seyfarth Shaw LLP on

The Department of Justice (DOJ) recently initiated a one-year pilot program to encourage companies to self-report violations of the Foreign Corrupt Practices Act (FCPA). Any company contemplating self-reporting such a...more

The Volkov Law Group

White Collar Criminal Sentencing – What A Difference Cooperation Makes

The Volkov Law Group on

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

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

Perkins Coie

DOJ Seeks to Boost Voluntary Disclosures Through FCPA Pilot Program

Perkins Coie on

In a move that follows long-standing complaints from the corporate community and the FCPA defense bar concerning the government’s vague assurances of “cooperation credit” in FCPA resolutions for self-reporting companies, on...more

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