Fraud, Yates Memorandum

Individual Accountability in AML Cases

Ballard Spahr LLP on 5/19/2017

This post discusses individual liability in AML/BSA enforcement, which is an area of increasing attention. Indeed, according to public statements by the government, individual liability is the focus of enhanced scrutiny...more

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

Pillsbury Winthrop Shaw Pittman LLP on 3/10/2017

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

You’re Fired: What Impact Will Sally Yates’ Departure Have on the DOJ’s Fraud Enforcement?

Snell & Wilmer on 2/9/2017

As most of the world now knows, President Trump fired acting Attorney General Sally Yates last week after she declined to defend the President’s travel ban. Dana Boente has replaced Ms. Yates, but he may not be long for the...more

"CFTC’s Enforcement Division Issues New Advisories on Cooperation"

Skadden, Arps, Slate, Meagher & Flom LLP on 2/7/2017

On January 19, 2017, the U.S. Commodity Futures Trading Commission’s Division of Enforcement issued two new enforcement advisories outlining the factors the division will consider in evaluating cooperation in the agency’s...more

DOJ Criminal Prosecution of Wells Fargo: What to Expect?

The Volkov Law Group on 10/19/2016

Compliance and enforcement headlines have focused on the Wells Fargo scandal. And for good reason. On September 8, 2016, the Consumer Financial Protection Bureau, the Comptroller of the Currency and the Los Angeles...more

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

Snell & Wilmer on 9/15/2016

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

FCPA Compliance---Recent Department of Justice Initiatives

Seyfarth Shaw LLP on 9/13/2016

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

Another Jury Acquits in One of the First Few Prosecutions of Health Care Executives Following DOJ’s Yates Memo

Mintz - Health Care Viewpoints on 7/27/2016

Last month, we reported on a Massachusetts federal court jury’s decision to acquit the former CEO of Warner Chilcott in one of the first prosecutions of a health care executive following the Department of Justice’s (“DOJ”)...more

New FCPA Guidance: DOJ Swings and Misses

Orrick, Herrington & Sutcliffe LLP on 4/8/2016

On April 5, 2016, the Fraud Section of the Criminal Division, Department of Justice ("DOJ") released a policy document entitled, The Fraud Sections' Foreign Corrupt Practices Act Enforcement Plan and Guidance ("Guidance"), in...more

DOJ Fraud Section to Require Cooperation Certifications Before Corporate Settlement

McGuireWoods LLP on 2/17/2016

Before settling with the U.S. Department of Justice’s Fraud Section, companies must now certify that they disclosed all information about individuals involved in the underlying misconduct. According to a recent Wall Street...more

Principal Deputy Assistant Attorney General Mizer on Yates Memo: “No Partial Credit for Cooperation that Doesn’t Include...

Arnall Golden Gregory LLP on 11/4/2015

Principal Deputy Assistant Attorney General Benjamin C. Mizer’s remarks at the 16th Pharmaceutical Compliance Congress and Best Practices Forum highlighted the Department of Justice’s “renewed commitment to ensuring that...more

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