News & Analysis as of

Self-Disclosure Requirements Cooperation

Thomas Fox - Compliance Evangelist

The Boston Consulting Group Declination: A Money Shot for Clawbacks

In a recent development that has garnered significant attention in the compliance community, the U.S. Department of Justice (DOJ) declined prosecution of Boston Consulting Group, Inc. (BCG) for violations of the Foreign...more

Snell & Wilmer

The Department of Justice Offers Individual Corporate Wrongdoers a “Get Out of Jail Free Card” in New Voluntary Self-Disclosure...

Snell & Wilmer on

The Department of Justice’s Criminal Division (DOJ) recently announced a Pilot Program on Voluntary Self-Disclosures for Individuals (the Individual VSD Pilot Program or Pilot Program), which allows certain individuals...more

The Volkov Law Group

DOJ Heralds New Voluntary Self-Disclosure Program for Individuals

The Volkov Law Group on

On April 15, 2023 Nicole Argentieri, Principal Deputy Assistant Attorney General and the Head of the U.S. Department of Justice’s (“DOJ’s”) Criminal Division, announced a new voluntary self-disclosure program for individuals...more

Mintz

DOJ’s Criminal Division Announces Pilot Program on Voluntary Self-Disclosure for Individuals

Mintz on

Drawing on a carrot and stick approach, Department of Justice (“DOJ” or the “Department”) guidance in 2023 focused heavily on incentivizing companies to voluntarily self-disclose their misconduct. This guidance included the...more

Venable LLP

DOJ Announces Pilot Program for Individual Voluntary Self-Disclosures

Venable LLP on

On April 15, 2024, the Department of Justice (DOJ) criminal division announced a new pilot program designed to reward individuals with non-prosecution agreements (NPAs) who voluntarily self-disclose "actionable, original...more

Mintz

EnforceMintz — DOJ’s Efforts in 2023 to Incentivize Voluntary Self-Disclosure

Mintz on

2023 was a very active one for Department of Justice (DOJ or the “Department”) guidance, and that guidance had one clear theme: DOJ wants companies to voluntarily self-disclose their misconduct. To incentivize...more

Holland & Knight LLP

"Call Us Before We Call You": SDNY Announces Pilot Whistleblower Program

Holland & Knight LLP on

The U.S. Attorney's Office for the Southern District of New York (SDNY) on Jan. 10, 2024, announced a Whistleblower Pilot Program (Program) that it is presenting as another "tool in [the SDNY's] toolkit" that could unearth...more

Thomas Fox - Compliance Evangelist

The SAP FCPA Enforcement Action-Part 4: The Fines: Self-Disclose, Self-Disclose, Self-Disclose

We continue our exploration of the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. Today we go full geek in a look at the fine and penalty and most importantly what the fine and penalty communicate about what the...more

Troutman Pepper

The Stick and the Carrot: DOJ Continues to Eye Corporate Crimes, While Encouraging Prompt Self-Disclosures of Misconduct...

Troutman Pepper on

On October 4, Deputy Attorney General (DAG) Lisa Monaco announced the Department of Justice’s (DOJ) new Safe Harbor Policy for voluntary self-disclosures made in connection with mergers and acquisitions (M&A). This policy is...more

American Conference Institute (ACI)

[Event] 40th International Conference on the FCPA - November 28th - 30th, National Harbor, MD

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

Robinson & Cole LLP

DOJ Announces Extension of Voluntary Self-Disclosure Guidance for Misconduct Discovered Through M&A Due Diligence

Robinson & Cole LLP on

On October 4, 2023, the U.S. Department of Justice (DOJ) announced a uniform approach for the resolution of voluntary self-disclosure (VSD) of misconduct discovered during M&A due diligence. The Mergers & Acquisitions Safe...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Compelled Interviews Admissible in Criminal Prosecution Against Former Company President and Its General Counsel

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

Carlton Fields

Catching More Flies With Honey: Recent DOJ Policy Changes to Coax Cooperation From Corporate Defendants

Carlton Fields on

In March 2023, the Department of Justice announced two policy changes that attempt to incentivize self-disclosure to the federal government and self-imposed remedial measures by corporations charged with criminal wrongdoing....more

Carlton Fields

Recent DOJ Guidance on Corporate Compliance, Cooperation, and Compensation

Carlton Fields on

Introduction - Over the first quarter of this year, the Department of Justice announced notable policy changes for corporate compliance programs. These policy changes are particularly relevant to in-house counsel who may...more

Morgan Lewis

US Attorneys Emphasize Benefits of New Voluntary Self-Disclosure Policy

Morgan Lewis on

Assistant Attorney General (AAG) Kenneth A. Polite Jr. of the US Department of Justice’s (DOJ’s) Criminal Division recently joined several high-profile, diverse US Attorneys at the inaugural Charlotte E. Ray Lecture and White...more

Hogan Lovells

DOJ’s Consumer Protection Branch rolls out new voluntary self-disclosure policy

Hogan Lovells on

On March 3, 2023, the Consumer Protection Branch (CPB) of the Civil Division of the U.S. Department of Justice (DOJ) publicly released a new voluntary self-disclosure policy (“CPB VSD Policy”). The CPB VSD Policy seeks to...more

Williams Mullen

DOJ Implements Corporate Self-Disclosure Policy for Criminal Misconduct

Williams Mullen on

A new voluntary self-disclosure policy issued by the United States Department of Justice (DOJ) provides incentives for companies that voluntarily report criminal misconduct by their employees or agents....more

Cranfill Sumner LLP

DOJ Announces Sweeping Voluntary Corporate Self-Disclosure Policy

Cranfill Sumner LLP on

In late February, the United States Attorneys for the Southern and Eastern Districts of New York announced a new “Voluntary Self-Disclosure Policy” (VSD Policy), effective immediately, that applies to all United States...more

American Conference Institute (ACI)

[Webinar] Anti-Corruption Brazil – FCPA Compliance and Enforcement in Brazil: DOJ and SEC Alumni Provide Critical Updates and the...

American Conference Institute’s expert faculty of DOJ and SEC alumni will update you with the most recent developments and risk factors confronting industry in Brazil and will lay out practical takeaways for satisfying the...more

Snell & Wilmer

DOJ Incentivizes Voluntary Self-Disclosure of Corporate Criminal Misconduct in Policy Directive to U.S. Attorneys’ Offices...

Snell & Wilmer on

On February 22, 2023, the Department of Justice (“DOJ”) announced that all 93 United States Attorneys’ Offices throughout the country are implementing, effective immediately, a Voluntary Self-Disclosure Policy (“Policy”) for...more

BakerHostetler

DOJ Announces Major Corporate Enforcement Policies

BakerHostetler on

Monaco’s and Polite’s remarks, and the DOJ’s new policies and guidance, come amid the Department’s increasingly tough on corporate crime approach and emphasis on rewarding companies that have effective compliance programs...more

Dorsey & Whitney LLP

Department of Justice Announces First-Ever Pilot Program on Compensation Incentives and Clawbacks, Revisions to Corporate Guidance...

Dorsey & Whitney LLP on

On March 2, 2023, in remarks delivered at the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco announced a new policy creating incentives for companies to adopt...more

Seward & Kissel LLP

DOJ Releases New Voluntary Self-Disclosure Policy

Seward & Kissel LLP on

On February 22, 2023, the Department of Justice (“DOJ”) released a new voluntary self-disclosure (“VSD”) policy (available here) that applies to all United States Attorney’s Offices (“USAO”). The policy details the...more

BakerHostetler

Confession, Cooperation and Corporate Compliance DOJ Rolls Out Nationwide Standards and Incentives for Voluntary Self-Disclosure

BakerHostetler on

Last week, the Department of Justice (DOJ or the Department) announced the immediate implementation of a new Voluntary Self-Disclosure Policy (the Policy), setting a nationwide standard for how U.S Attorneys’ Offices will...more

Goodwin

DOJ Announces Nationwide Voluntary Corporate Self-Disclosure Policy in Effort to Standardize and Incentivize Timely Self-Reporting

Goodwin on

On February 22, 2023, the US Department of Justice (DOJ) announced a Voluntary Self-Disclosure Policy (VSD Policy) to formalize DOJ’s efforts to incentivize companies to voluntarily self-report criminal misconduct to the...more

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