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Penalties Self-Disclosure Requirements

Snell & Wilmer

Department of Justice Announces Groundbreaking Whistleblower Program in its Ongoing Effort to Incentivize Voluntary Self...

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Department of Justice (DOJ) Deputy Attorney General Lisa Monaco announced that the DOJ is adopting a whistleblower incentive program today at the American Bar Association’s 39th National Institute on White Collar Crime. In...more

Akin Gump Strauss Hauer & Feld LLP

BIS Announces Key Updates to Voluntary Self-Disclosure Process

Key Points - On January 16, 2024, Matthew Axelrod, Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s BIS announced key updates to BIS’s VSD process. The updates are also now reflected on BIS’s...more

K2 Integrity

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Consolidating Information Regarding Voluntary Self-Disclosure Policies

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The U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published their second Tri-Seal...more

McDermott Will & Emery

[Webinar] 2023 Enforcement Outlook Series: Protecting Your Business Against Non-Compliance and DOJ Penalties - March 23rd, 12:00...

McDermott Will & Emery on

During speeches earlier this month, Deputy Attorney General Lisa Monaco and Assistant Attorney General for the Criminal Division Kenneth A. Polite, Jr. announced significant changes to the way DOJ evaluates corporate...more

Smith Gambrell Russell

U.S. Attorneys’ Office Issues New “Self-Disclosure” Penalty Policy for Environmental Crimes

Smith Gambrell Russell on

On February 22, the U.S. Attorneys’ Office issued a new, voluntary self-disclosure policy encouraging companies to reveal potentially criminal conduct for environmental crimes. For qualifying self-disclosures, the policy can...more

Ankura

Key Compliance Takeaways from DOJ Memorandum

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“Further Revisions to Corporate Criminal Enforcement Policies Following Discussions with Corporate Crime Advisory Group” - Compliance programs play a critical role for healthcare organizations, ensuring both individuals...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – January 2023

Russia - Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating U.S. Sanctions on Russia (DOJ) Those involved. Charles McGonigal, former Special Agent in Charge of the FBI...more

Snell & Wilmer

CFIUS Releases Guidance Concerning Enforcement and Penalty Actions

Snell & Wilmer on

On October 20, 2022, the Committee on Foreign Investment in the United States (“CFIUS”) issued the “CFIUS Enforcement and Penalty Guidelines” (the “Guidelines”). These are the first-ever Guidelines issued by CFIUS which is a...more

King & Spalding

Treasury Publishes First-Ever CFIUS Enforcement and Penalty Guidance

King & Spalding on

Publication indicates a more robust enforcement posture - On October 20, 2022, the U.S. Department of the Treasury (“Treasury”) released the first-ever Enforcement and Penalty Guidelines (the “Guidelines”) for the...more

Holland & Knight LLP

CFIUS Enforcement and Penalty Guidelines Enhance Transparency for Cross-Border Dealmakers

Holland & Knight LLP on

The Committee on Foreign Investment in the United States (CFIUS) released the first-ever CFIUS Enforcement and Penalty Guidelines (Guidelines) on Oct. 20, 2022, providing the public a roadmap describing three categories of...more

Ankura

BIS Issues Important Policy Changes on Trade Controls Violations Prevention and Enforcement

Ankura on

Matthew Axelrod, the Assistant Secretary of Commerce for Export Enforcement with the Department of Commerce, recently made two important statements on how the Department will enforce trade controls and address violations....more

Davies Ward Phillips & Vineberg LLP

First Remediation Agreement under the Canadian Criminal Code: Key Takeaways

The Superior Court of Québec recently published its reasons1 approving Canada’s first remediation agreement under the Criminal Code, which is Canada’s version of a deferred prosecution agreement (DPA). In his reasons, the...more

Husch Blackwell LLP

BIS Modifies and Expands List of Russian-Controlled Aircraft Subject to the EAR Known or Suspected to Have Violated the EAR

Husch Blackwell LLP on

On March 30, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) modified and expanded a list of aircraft that have flown into Russia in apparent violation of the Export Administration Regulations...more

Holland & Hart LLP

EPA Under Biden Signals Continuing Importance of Self-Disclosure

Holland & Hart LLP on

On February 5, 2021, the U.S. Environmental Protection Agency (EPA) issued updated Frequently Asked Questions (FAQs) regarding its Audit Policy Program, signaling that the Biden Administration will continue to support...more

Holland & Knight LLP

DOJ Makes Permanent Its Program to Incentivize Self-Disclosure in FCPA Investigations

Holland & Knight LLP on

• The U.S. Department of Justice's (DOJ) pilot program established in 2016 to incentivize companies to self-report violations of the Foreign Corrupt Practices Act (FCPA) will, with slight revisions, be made permanent. •...more

Ballard Spahr LLP

MDE Self-Disclosure Can Limit, Even Eliminate Risk of Environmental Penalties

Ballard Spahr LLP on

Maryland entities that voluntarily discover and disclose environmental violations can still receive penalty reductions, or even complete forgiveness, under the rarely invoked Maryland Department of the Environment (MDE)...more

Baker Donelson

2013 Healthcare Fraud and Abuse Bootcamp Webinar Series, Part V: Compliance

Baker Donelson on

Bill Mathias of Ober|Kaler's Health Law Group presented on compliance as a part of the 2013 Healthcare Fraud and Abuse Bootcamp Webinar Series sponsored by the American Health Lawyers Association. This webinar...more

Thomas Fox - Compliance Evangelist

Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA

In the two most recent corporate Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) to communicate not only what they believe constitutes a...more

Thomas Fox - Compliance Evangelist

Actions Taken During A FCPA Enforcement Action - Lessons From Parker Drilling And Ralph Lauren

In the two most recent corporate Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) to communicate not only what they believe constitutes a...more

Thomas Fox - Compliance Evangelist

What’s The Message From BizJet? Self-Disclose And Cooperate

Over the past week there has been a plethora of Foreign Corrupt Practices Act (FCPA) enforcement actions released. One group was the four enforcement actions involving individuals concerning BizJet. While I cannot say that...more

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