What the Board Should Be Asking About the Compliance Program
Common Scenarios Triggering False Claims Act Violations, Part 3: Claims and Investigations
False Claims Act Insights - The Art and Science of Corporate Compliance in Managing FCA Risk
An Ounce of Prevention: Keys to Understanding and Preventing AI and Cybersecurity Risks
Behavioral Health Compliance
The Justice Insiders Podcast: Using External Resources for Internal Investigations
Bank Investigations and Enforcement Actions: Lessons Learned — The Consumer Finance Podcast
The Justice Insiders Podcast: SEC Plays Chicken with Jarkesy
What Nonprofit Board Leadership Needs To Know About Internal Investigations
Compliance Series Part 3: Ensuring Compliance Programs are Effective
Compliance Programs Part 2: Designing a Successful Compliance Program
Compliance Programs Part 1: What is a Compliance Program and Why do Businesses Need One?
How to Combat Corporate Theft: Office Space - Hiring to Firing Podcast
All Things Investigations: Episode 28 - New French Anti-Corruption Investigative Guidance with Anne Gaustad and Bryan Sillaman
Investigative Power: Utilizing Self Service Solutions for Internal Investigations?
Internal Investigations and the Food, Beverage and Agribusiness Industry
CyberSide Chats: Cyber Law, Cybersecurity, and Whistleblowers. A Conversation with Ben Wright
Internal Investigations for Nonprofits: A Means of Identifying and Addressing Misconduct Before the Regulators Come Calling
Nuts and Bolts of a Repayment Investigation: Keys to Conducting Investigations Under the 60-Day Repayment Rule
Internal Investigations in the Asia-Pacific Region
A New Jersey federal court has ruled that a company’s self-disclosure of potential Foreign Corrupt Practices Act (FCPA) violations did not render the company a state actor, allowing evidence obtained by its internal...more
On June 2, the French ministry of Justice released a new order addressed to French prosecutors on the criminal policy relating to international corruption and how such cases should be handled. In this order, which...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
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 changes to the Department of Justice’s policy concerning individual accountability in corporate cases, stating that “pursuing individuals responsible for...more
Beginning with the Department of Justice’s (DOJ’s) Yates Memo, its Foreign Corrupt Practices Act (FCPA) Pilot Program and then the release of the Evaluation of Corporate Compliance Programs (Evaluation), I believe the DOJ has...more
Properly Scoped Investigation by Qualified Personnel – How has the company ensured that the investigations have been properly scoped, and were independent, objective, appropriately conducted, and properly documented? These...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
Every year it’s safe to assume that our list of Top 10 trends will include the latest developments pertaining to helplines, whistleblower reporting and retaliation, and this year is no exception. We begin by examining some...more
Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more
The guidance issued by the DOJ in connection with the Pilot Program and recent declinations state that disclosure, remediation and cooperation are essential to any favorable resolution with the government. Six months...more
The Business Law Section’s Director and Officer Liability Committee conducted a program at the Section’s Spring Meeting in Montréal. The program focused on the recent Yates memorandum of the U.S. Department of Justice (DOJ),...more
As we continue to operate under the Yates Memorandum, a number of interesting and difficult issues are sure to develop surrounding internal investigations and individual culpability. Corporate internal investigations have to...more
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
This week, the Fraud Section of the Department of Justice (DOJ) announced a pilot program that extends additional “mitigation credit” to qualifying companies that “fully cooperate” in matters involving the Foreign Corrupt...more
The Department of Justice (“DOJ”) is setting its sights on individual accountability for corporate wrongdoing. That is the message that DOJ has been promoting following the recent internal memorandum issued by Deputy Attorney...more
On October 22, 2015, the U.S. Department of Justice Principal Deputy Assistant Attorney General Benjamin C. Mizer, who oversees DOJ’s Civil Division, spoke at the 16th Pharmaceutical Compliance Congress and Best Practices...more
The Justice Department’s recent Yates memorandum on individual accountability is a significant event. Sure, you can always find members of the FCPA Paparazzi who will discount the memo, or relegate it to a mere “political”...more
On September 9, 2015, United States Deputy Attorney General Sally Yates released a memorandum titled “Individual Accountability for Corporate Wrongdoing,” the latest in a series of corporate prosecution guidelines written by...more
The United States Department of Justice (DOJ) recently issued a memorandum to various enforcement agencies. The memorandum, available here, focuses on holding individuals accountable for corporate fraud and misconduct. The...more
The U.S. Department of Justice (DOJ) recently issued a memorandum ("The Yates memo") on September 9, 2015 by Deputy Attorney General Sally Yates, reaffirming the Government's commitment to prosecuting individuals. Say...more
Earlier this month, we discussed a memorandum issued by Deputy Attorney General Sally Quillian Yates of the U.S. Department of Justice (DOJ). This memorandum, referred to as the “Yates Memo,” reaffirms the Government’s...more
On September 9, 2015, the Department of Justice ("DOJ") issued written guidance by the Deputy Attorney General Sally Quillen Yates on investigating and prosecuting individuals involved in alleged corporate wrongdoing (the...more
On September 22, 2015, the U.S. Department of Justice’s Assistant Attorney General in charge of the Criminal Division, Leslie R. Caldwell, spoke at the Global Investigations Review Conference in New York, addressing the...more