Auditing and Monitoring in Healthcare
New DOJ Guidance Tightens Corporate Enforcement Strategy
Health Care Continues to Drive False Claims Act Recoveries: Thought Leaders in Health Law Video Series
Accountability: At the Heart of Compliance-Boeing, Part 1-Accountability from Employees
Unfair and Unbalanced-Episode 18
Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more
Hosted by American Conference Institute, the 13th West Coast Forum on FCPA Enforcement and Compliance returns for another exciting year, providing the opportunity to connect with decision-makers from your industry, gather...more
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
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
This year, 2020, has been an enforcement year opening with billion-dollar settlements: first, Airbus settled FCPA charges for $4 billion, and now Wells Fargo for $3 billion. What a start to an enforcement year!...more
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
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
The European Union (“EU”) recently has grappled with a series of massive money laundering scandals and strategized about how to more effectively combat international money laundering and corruption. Generally, the EU has...more
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
In November, the U.S. Department of Justice revised principle 9-28.700 – The Value of Cooperation in its Justice Manual – aka the Yates Memo....more
On November 29, 2018, in a speech at the 35th International Conference on the Foreign Corrupt Practices Act, U.S. Deputy Attorney General Rod Rosenstein announced the Department of Justice’s (DOJ or the Department) revised...more
On November 29, 2018, at the American Conference Institute’s International Conference on the Foreign Corrupt Practices Act in National Harbor, Maryland, Mr. Rosenstein announced noteworthy policy changes related to the...more
During this week, I have been considering last week’s Department of Justice (DOJ) and Securities and Exchange Commission (SEC) pronouncements about where 2018 Foreign Corrupt Practices Act (FCPA) enforcements have been and...more
In a November 29, 2018 speech, Deputy Attorney General Rod Rosenstein announced a softening of the US Department of Justice’s (DOJ) policy on giving credit for cooperation in corporate prosecutions. As memorialized in the...more
On November 29, 2018, Deputy Attorney General Rod Rosenstein announced revisions to the Department of Justice (“DOJ”) policy on individual accountability for corporate wrongdoing, which was originally announced in the Yates...more
In a speech delivered on Thursday, Nov. 29, 2018, Deputy Attorney General Rod Rosenstein described important changes to DOJ policies for awarding cooperation credit in corporate investigations. These changes have been...more
On November 29, 2018, Deputy Attorney General Rod Rosenstein announced changes to the Department of Justice’s policy concerning individual accountability in corporate cases, stating that “pursuing individuals responsible for...more
On November 29, 2018, the US Department of Justice (DOJ) modified prior guidance on individual liability for corporate misconduct by affording federal prosecutors discretion to focus on “individuals who play significant roles...more
On November 29, Deputy Attorney General Rod Rosenstein announced revisions to the Department of Justice’s policy on corporate cooperation in government investigations, which may make it easier for companies under...more
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
In a speech last week, Criminal Division Assistant Attorney General Leslie Caldwell touted the success of the FCPA Pilot Program. AAG Caldwell outlined the success of the FCPA enforcement program, listing many of the...more
The second day of the SCCE Compliance and Ethics Institute (CEI) Conference began with Principal Deputy Associate Attorney General Bill Baer providing remarks. After opening with how aggressively the Department of Justice...more
On April 5, 2016, the U.S. Department of Justice (DOJ) issued an Enforcement and Guidance Plan (Plan) concerning the Foreign Corrupt Practices Act (FCPA). While the new Plan could be interpreted as a novel departure from past...more
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
Companies face an ever-changing constellation of risks, enforcement priorities and demands for internal controls and compliance program elements. As more resources are poured into government enforcement programs, companies...more