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Latham & Watkins LLP

SFO Announces Ambitious Five-Year Plan

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The Serious Fraud Office’s strategy for 2024 to 2029 indicates aspiration to be a more effective agency and to incentivise personnel. On 18 April 2024, the UK’s Serious Fraud Office (SFO) published an ambitious, albeit...more

Bradley Arant Boult Cummings LLP

DOJ Takes the Next Step in Its Effort to Increase Voluntary Self-Disclosures By Incentivizing Those Complicit in Wrongdoing

On April 15, the U.S. Department of Justice released The Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals (the “Pilot”) designed to encourage individuals to report certain types of criminal...more

Bradley Arant Boult Cummings LLP

“Take Me to the Pilot” – DOJ Announces Plan to Entice Self-Disclosures of Government Contract Fraud

On April 15, the U.S. Department of Justice released The Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals (the Pilot) designed to encourage individuals to report certain types of criminal...more

Proskauer - Employee Benefits & Executive...

DOL Unveils Final Amendment to QPAM Exemption

On April 3, 2024, the U.S. Department of Labor (the “DOL”) published in the federal register a final amendment to Prohibited Transaction Class Exemption 84-14 (the “QPAM Exemption”) that makes considerable changes to the...more

Dechert LLP

Not Quite QPAMDEMONIUM: DOL Issues Final Changes to the QPAM Exemption

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On April 3, 2024, the Department of Labor (the “DOL”) issued its final amendment (“Final Amendment”) to Prohibited Transaction Class Exemption 84-14, commonly referred to as the “QPAM Exemption”. Generally, the QPAM...more

Seward & Kissel LLP

DOL Finalizes Amendments to the QPAM Exemption – All QPAMs Must Take Action

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On April 3, 2024, the U.S. Department of Labor (DOL) published significant modifications to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption). The amendment becomes effective on June 17, 2024; however, certain...more

ArentFox Schiff

SDNY Whistleblower Program for Individuals: An Extension of DOJ Corporate Voluntary Disclosure Policies

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On January 10, when announcing his office’s new Whistleblower Pilot Program, Southern District of New York United States Attorney Damian Williams told potential cooperators “[c]all us before we call you.” But should you? ...more

Mintz

EnforceMintz — DOJ’s Limited Use of NPAs and DPAs in Criminal Health Care Investigations

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In January 2023, the Criminal Division of the Department of Justice (DOJ) announced revisions to its Corporate Enforcement Policy (CEP), which we previously summarized here and discussed in further detail as part of...more

Paul Hastings LLP

More Clarity on the Horizon for FCPA Resolutions? DOJ and SEC Officials Discuss Enforcement Trends

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On November 28–30, 2023, the American Conference Institute’s 40th International Conference on the Foreign Corrupt Practices Act (“FCPA”), held in Washington, D.C., brought together prosecutors, regulators, corporate...more

HaystackID

Cooperation Standards in Government Investigations: Practical Tips

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Editor’s Note: From time to time, ComplexDiscovery highlights publicly available or privately purchasable announcements, content updates, and research from cyber, data, and legal discovery providers, research organizations,...more

BakerHostetler

DOJ Corporate Compliance Certifications Appear to Be Here to Stay

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The compliance certification policy was first announced by Assistant Attorney General (Assistant AG) Kenneth Polite in March 2022, when he stated that for all criminal division “corporate resolutions (including guilty pleas,...more

Vinson & Elkins LLP

DOJ Chooses Sticks Over Carrots: Three Reasons Why Changes to DOJ’s Corporate Enforcement Policy May Chill Cooperation by...

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In announcing recent changes to its corporate criminal enforcement policies, the Department of Justice (“DOJ” or the “Department”) continued its forceful “tough on crime” initiatives to deter wrongdoing....more

Morrison & Foerster LLP

Deputy Attorney General Lisa Monaco Announces Changes to DOJ’s Corporate Criminal Enforcement Policies

On September 15, 2022, the U.S. Department of Justice (DOJ)’s Deputy Attorney General Lisa Monaco announced new guidance and policies regulating corporate criminal enforcement. The new policies emphasize that DOJ will not...more

Lowenstein Sandler LLP

Deputy Attorney General Lisa O. Monaco Doubles Down on Prior Commitment to Aggressively Prosecute Corporate Crime

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On September 15, 2022, the Department of Justice (“DOJ”) announced several important changes to its policies for prosecuting corporate crime. Deputy Attorney General Lisa O. Monaco, who made the announcement in a speech at...more

A&O Shearman

DOJ announces new policies on corporate prosecution

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In a speech on September 15, 2022 and in a memo of the same date, U.S. Department of Justice (DOJ) Deputy Attorney General Lisa Monaco announced several new policies and issued several directives regarding the DOJ’s...more

McGuireWoods LLP

New DOJ Guidance on Corporate Criminal Enforcement

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On Sept. 15, 2022, U.S. Deputy Attorney General Lisa Monaco announced important guidance and new actions from the U.S. Department of Justice (DOJ or the Department) on corporate criminal enforcement. Her remarks, delivered at...more

Latham & Watkins LLP

The International Investigations Review, 12th Edition - England & Wales

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In its second year, the Biden administration has made clear its prioritisation of white-collar prosecutions. This includes changes in policy and guidance, such as a renewed focus on individual accountability, an increased...more

American Conference Institute (ACI)

DOJ CCO Certification Requirement Will Up the Ante of CCO Oversight

Officials with the U.S. Department of Justice have portended a sea change in the oversight responsibilities of chief compliance officers (CCOs) as it concerns corporate resolutions going forward. In public remarks made March...more

Society of Corporate Compliance and Ethics...

Federal Monitorships and Making Them Work

For a time monitorships were, if not endangered, out of favor. After many years of embracing them, the US Department of Justice had begun calling for cost benefit analyses and looking for alternatives. Then in 2021 Deputy...more

Hogan Lovells

Stericycle DPA signals more aggressive use of independent compliance monitors

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On April 20, 2022, the U.S. Department of Justice (DOJ) announced it had entered a three-year deferred prosecution agreement (DPA) with Stericycle Inc. to resolve allegations that it violated the Foreign Corrupt Practices Act...more

Torres Trade Law, PLLC

There’s A New Compliance Sheriff In Town, And She’s Cracking Down On Corporate Misconduct

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The U.S. Department of Justice ("DOJ") is making it harder on companies that commit corporate crimes. A lot harder. That’s the message that Deputy Attorney General Lisa Monaco recently gave attendees at the American Bar...more

Thomas Fox - Compliance Evangelist

Not Your Father’s Monitor – Bethany Hengsbach on White Collar Enforcement and Defense

In October, Deputy Attorney General (DAG) Lisa O. Monaco gave a Keynote Address at ABA’s 36th National Institute on White Collar Crime (Monaco Speech). Her remarks reframed a discussion about the uses of, reasons for and...more

Vinson & Elkins LLP

Why Voluntary Independent Compliance Monitorships Are Growing in Popularity

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When companies get into trouble, it’s common practice for the government to call on independent third parties to help clean up the mess. Companies under investigation by the Department of Justice (“DOJ”) often agree to...more

Holland & Hart LLP

DOJ Announces Significant Changes to Corporate Criminal Enforcement Policies

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On October 28, 2021, Deputy Attorney General Lisa Monaco issued a Memorandum entitled “Corporate Crime Advisory Group and Initial Revisions to Corporate Criminal Enforcement Policies,” which she explained the same day in her...more

ArentFox Schiff

"When It Comes To Corporate Crime, the DOJ Means Business"

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Deputy Attorney General Lisa O. Monaco’s Keynote Address at ABA's National Institute on White Collar Crime - Despite having been delivered virtually, Deputy Attorney General Monaco’s message to white collar counsel came...more

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