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Individual Accountability Corporate Misconduct

Womble Bond Dickinson

Criminal Division of U.S. Department of Justice Announces Pilot Program on Voluntary Self-Disclosure for Individuals

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In the U.S. Department of Justice’s (DOJ) latest policy in furtherance of its “carrots and sticks” approach to corporate criminal enforcement, senior leadership of its Criminal Division announced a new Pilot Program on...more

BCLP

New DOJ Pilot Program Incentivizes Individuals to Report Criminal Conduct

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Companies beware! The U.S. Department of Justice (DOJ) announced a pilot program “designed to encourage voluntary self-disclosure by individual participants in certain types of criminal conduct involving corporations.” In...more

Dorsey & Whitney LLP

DOJ’s Criminal Division Launches New Self-Disclosure Pilot Program for Individuals

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On April 15, 2024, the U.S. Department of Justice (DOJ)’s Criminal Division announced a new pilot program that will allow and encourage individuals involved in specific types of corporate criminal conduct to voluntarily...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

DOJ’s Emphasis Of Individual Accountability – Where It Stands, And Where It Could Be Headed

A recent article in Law360 sparked a vigorous conversation among members of Pietragallo’s white collar practice group about the current state of the U.S. Department of Justice’s (DOJ) evolving emphasis on individual...more

King & Spalding

Reconsider That Term Sheet: DOJ "Safe Harbor Policy" Announcement Incentivizes Merger-Related Disclosures

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On October 4, 2023, the Department of Justice’s (“DOJ”) Deputy Attorney General Lisa Monaco announced a new “Mergers & Acquisitions Safe Harbor Policy” (“M&A Safe Harbor Policy” or “Policy”) for companies that voluntarily...more

Guidepost Solutions LLC

U.S. Attorneys’ Offices Voluntary Self-Disclosure Policy - Watch Out for The Next Logical Step – Enforcement

It is safe to assume that the United States Attorneys’ Offices Voluntary Self-Disclosure Policy announced on March 2, 2023 is intended to decrease wrongdoing and impose rehabilitation and recovery for victims. But...more

Rivkin Radler LLP

DOJ Issues New Guidance on Criminal Enforcement _ Winter 2023

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On September 15, 2022, Deputy Attorney General (“DAG”) Lisa Monaco delivered remarks announcing updated guidance on how the Department of Justice will be prioritizing and prosecuting corporate crime. Her remarks were...more

Brownstein Hyatt Farber Schreck

DOJ Rolls Out Corporate Self-Disclosure Policy to Be Enforced by U.S. Attorney’s Offices

On Feb. 22, 2023, the U.S. Department of Justice announced a new Voluntary Self-Disclosure Policy to encourage self-disclosure of potential criminal activity in exchange for varying levels of amnesty from criminal charges....more

Foodman CPAs & Advisors

Corporate Crime At The Forefront Of The DOJ

On September 15, 2022, Department of Justice (DOJ) Deputy Attorney General Lisa Monaco delivered remarks on Corporate Criminal Enforcement at the NYU Program on Corporate Compliance and Enforcement and announced new guidance...more

Rivkin Radler LLP

DOJ Issues New Guidance on Criminal Enforcement

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On September 15, Deputy Attorney General (“DAG”) Lisa Monaco delivered remarks announcing updated guidance on how the Department of Justice will be prioritizing and prosecuting corporate crime....more

Ankura

DAG Monaco Defines DOJ Guidance for Corporate Criminal Enforcement

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New Requirements Place Onus on Corporations to Demonstrate more Compliance Capabilities to Receive Consideration from Prosecutors On September 15, 2022, Deputy Attorney General (“DAG”) Lisa Monaco spoke at New York...more

Bracewell LLP

DOJ to Companies: If You Step Up & Own Up, You Might Not Have to Pay Up

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Late last year, the Department of Justice (DOJ) announced material changes to the way it intended to investigate, prosecute, and resolve corporate cases. The changes were aggressive, leading us to title our update “DOJ’s...more

Dechert LLP

DOJ Announces Substantial Revisions to Corporate Enforcement Policy

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Late last week, the Department of Justice’s Deputy Attorney General, Lisa Monaco, announced several new guidelines for prosecutors to use when determining how to assess and treat corporate offenders....more

Dorsey & Whitney LLP

DOJ Paving a More Structured Path for Corporate Criminal Enforcement

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​​​​​​​On September 15, 2022, Deputy Attorney General Lisa Monaco laid out the DOJ’s first substantive changes to white-collar criminal investigations and enforcement under the Biden administration....more

Womble Bond Dickinson

DOJ Announcements on Corporate Criminal Enforcement: Defining the Carrots and Sticks

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The Department of Justice (DOJ) has been touting revisions to its corporate criminal enforcement policies and signaling increased action for nearly a year. Yesterday, Deputy Attorney General Lisa O. Monaco formally announced...more

BakerHostetler

Attorney General Merrick Garland Emphasizes Criminal Corporate Enforcement and Individual Accountability

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On March 3, 2022, Attorney General Merrick B. Garland delivered a speech at the ABA Institute on White Collar Crime that underscored the Department of Justice’s (DOJ) commitment to prosecuting corporate crime and holding...more

A&O Shearman

U.S. Attorney General Announces Task Force To Target Russian Sanctions And Additional Resources For White Collar Enforcement

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U.S. Attorney General Merrick Garland made two announcements this week related to the enforcement of white-collar crime by both individuals and corporations. First, on March 2, 2022, Attorney General Garland announced the...more

Holland & Knight LLP

AG Merrick Garland: DOJ Prioritizing Prosecution of Individuals in White Collar Crime

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In remarks to the American Bar Association (ABA) Institute on White Collar Crime on March 3, 2022, Attorney General Merrick Garland underscored the U.S. Department of Justice's (DOJ) renewed emphasis on corporate...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Emphasizes Transparency and Encourages Cooperation

In 2019, the Criminal Division of the U.S. Department of Justice (DOJ) continued its efforts, begun a few years prior, to enhance transparency with respect to the DOJ's prosecutorial decision-making. In public statements, DOJ...more

Skadden, Arps, Slate, Meagher & Flom LLP

Transatlantic Approach on Corporate Cooperation: How Newly Issued French and UK Guidance Compare to US Practices

As widely anticipated, French and U.K. regulators recently published guidance detailing their expectations for corporate cooperation in enforcement investigations. Both sets of guidance demonstrate further alignment of those...more

Sheppard Mullin Richter & Hampton LLP

Feds Focus on Individuals in Evaluating Corporate Compliance Programs

Earlier this month, the U.S. Department of Justice (“DOJ”) and the U.S. Department of the Treasury’s Office of Foreign Asset Controls (“OFAC”) both issued guidance regarding their expectations for corporate compliance...more

Bass, Berry & Sims PLC

DOJ Trumpets “First-Ever” Criminal Indictment for Failure to Report Product Safety Issues

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On March 29, 2019, the U.S. Department of Justice (DOJ) announced it had initiated the first-ever criminal prosecution of individual business executives for alleged failure to timely disclose product safety issues to federal...more

Farella Braun + Martel LLP

Individual Accountability in the Huawei Trade Secrets Prosecution

In the ongoing legal battle over the alleged theft of American trade secrets by Chinese telecom giant Huawei, one curious aspect is the lack of charges filed against any individual Huawei employees. On February 28, Huawei...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2019 Insights: DOJ Policies Aim to Reduce Enforcement Burden on Cooperating Entities

The Department of Justice (DOJ) appears to be continuing to revamp its approach to companies suspected of financial crimes, and emphasize the importance of prosecutions of individuals. In a number of speeches in 2018, senior...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2019 Insights: SEC Continues Steady Progress With Regulatory, Enforcement Goals

As the Securities and Exchange Commission (SEC) enters the third year of the Trump administration, its regulatory and enforcement goals remain largely unchanged. At the direction of Chairman Jay Clayton, the SEC continues to...more

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