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Snell & Wilmer

DOJ Revisits its Corporate Criminal Enforcement Policy Offering Companies Additional Incentives to Self-Disclose, Cooperate, and...

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On January 17, 2023, Assistant Attorney General (“AAG”) Kevin Polite announced revisions to the Department of Justice’s (“DOJ”) Corporate Enforcement Policy (“CEP”), which will apply to all corporate criminal matters. The...more

Holland & Knight LLP

DOJ Makes Significant Revisions to Corporate Enforcement Policy

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The U.S. Department of Justice (DOJ), through Assistant Attorney General Kenneth A. Polite Jr., announced on Jan. 17, 2023, "the first significant changes" to its Corporate Enforcement Policy (CEP) since 2017. The revisions...more

Bracewell LLP

DOJ Issues New Policy Encouraging Self-Reporting FCPA Violations

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On November 29, 2017 the Deputy Attorney General of the U.S. Department of Justice (DOJ), Rod J. Rosenstein, announced a new FCPA enforcement policy that seeks to incentivize voluntary self-reporting by providing companies...more

Bradley Arant Boult Cummings LLP

DOJ’s FCPA Corporate Enforcement Policy Creates Greater Certainty for Companies

The Foreign Corrupt Practices Act of 1977 (FCPA) makes it unlawful for certain classes of persons and entities to make payments to foreign government officials to assist in obtaining or retaining business. On November 29,...more

Jones Day

DOJ's New FCPA Enforcement Policy Continues its "Carrot-and-Stick" Approach

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The Situation: Companies that learn of Foreign Corrupt Practices Act ("FCPA") violations by employees or agents are faced with significant uncertainty as to whether the benefits and risks of self-disclosing the conduct to the...more

Ruder Ware

Sally Yates’ was Already Famous for Changing the Focus of Compliance Investigations - The Yates Memorandum

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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

Dorsey & Whitney LLP

Dorsey Anti-Corruption Digest - April 2016

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Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more

Pillsbury Winthrop Shaw Pittman LLP

New FCPA Self-Reporting Pilot Program Formalizes Rewards but Relies on Discretionary Implementation

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

Clark Hill PLC

DOJ's New FCPA Guidance and Pilot Program

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On April 5, 2016, in an effort to bolster FCPA Compliance, the Department of Justice issued its "Foreign Corrupt Practices Act Enforcement Plan and Guidance" identifying the following three steps to enhance its FCPA...more

BakerHostetler

DOJ Attempts to Encourage Corporate Self-Disclosures With the Announcement of a One-Year FCPA Pilot Program

BakerHostetler on

Pursuing a classic “carrot and stick” approach to incentivizing corporate self-disclosure of FCPA violations and individual wrongdoing connected to FCPA violations, the Department of Justice (DOJ) Fraud Section announced a...more

Bracewell LLP

DOJ Launches FCPA Pilot Program to Promote Company Self-Reporting

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In a speech delivered last Wednesday by Assistant Attorney General Leslie Caldwell, the Justice Department’s (“DOJ”) Criminal Division announced the launch of a new Foreign Corrupt Practices Act (“FCPA”) “pilot program” that...more

Miller Canfield

DOJ’s Fraud Section Issues Foreign Corrupt Practices Act Enforcement Plan and Guidance

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On April 5, 2016, the Department of Justice’s Fraud Section (“DOJ”) issued its Foreign Corrupt Practices Act (“FCPA”) Enforcement Plan and Guidance (“Guidance”), which announced (1) a more than doubling of DOJ resources...more

Parker Poe Adams & Bernstein LLP

Is Confession Good for the Corporate Soul?: DOJ announces new mitigation credit for self-disclosure of FCPA violations

On April 5, 2016, the Department of Justice’s (“DOJ”) Fraud Section Chief, Andrew Weissmann, issued a memo (the “Weissmann Memorandum”) announcing a one-year Pilot Program that offers a carrot and stick approach to...more

WilmerHale

DOJ Launches FCPA Pilot Program to Encourage Corporate Voluntary Disclosure and Cooperation

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On April 5, 2016, the Fraud Section of the Department of Justice's (DOJ) Criminal Division issued an enforcement plan and guidance (the Guidance) laying out three steps it is taking to intensify Foreign Corrupt Practices Act...more

Foley & Lardner LLP

DOJ Fraud Section Offers Super Credit in FCPA Pilot Program

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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

Dorsey & Whitney LLP

DOJ Announces One-Year FCPA Enforcement Pilot Program

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The U.S. Department of Justice (“DOJ”) Criminal Division yesterday announced that its Fraud Section’s Foreign Corrupt Practices Act (“FCPA”) Unit is conducting a one-year FCPA enforcement pilot program (“Program”). A company...more

BCLP

DOJ’s “Half Off” Deals for Self-Reporting FCPA Misconduct: Certain Exclusions Apply, See Below for Details

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For the next year, the Justice Department may be offering up to a 50% discount on fines imposed in FCPA cases. Yesterday, the U.S. Department of Justice’s (“DOJ”) Criminal Division announced the launch of a one-year pilot...more

Proskauer - Corporate Defense and Disputes

Criminal Division Launches New FCPA Pilot Program

On April 5, 2016, the Department of Justice upped the ante in its efforts to encourage companies to self-report potential Foreign Corrupt Practices Act (“FCPA”) violations when it unveiled a one-year pilot program that...more

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