FCPA Compliance Report - James Koukios on the Monaco Speech
Compliance Into The Weeds: DAG Announces Changes in Enforcement Priorities
Nota Bene Episode 29: The Essential Elements of Effective Corporate Compliance Programs with Jim McGinnis
Day 13 of One Month to Better Investigations and Reporting-The Yates Memo and Internal Investigations
Day 9 of One Month to Better Reporting and Investigations-The Investigation Team
Day 8 of One Month to Better Investigations and Reporting Day 8-Preparing for the Investigation
Everything Compliance-Episode 11, the first 100 Days of the Trump Administration, Part II
FCPA Compliance Report-Episode 319-Brandon Essig on Prosecutor's View of the Yates Memo
Internal Investigations: The Impact of the Yates Memo, the FCPA Unit Pilot Program and Recent Legal Decisions
This Week in FCPA-Episode 1
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
In this episode of the FCPA Compliance Report, I am joined by fan-favourite James Koukios, a partner at Morrison and Foerster, and we take a deep dive into the Lisa Monaco speech from October and related remarks from other...more
There is almost universal agreement regarding predictions for 2022 federal enforcement in the following areas: ..The use of fraudulently obtained COVID relief funds in both healthcare and in general, but specifically as...more
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
Just one year after President Biden’s election, senior administration officials have signaled in public remarks that the federal government will amplify enforcement pressure on corporations and their employees through...more
On October 28, 2021, Deputy Attorney General (Deputy AG) Lisa O. Monaco gave remarks explicitly warning companies that the US Department of Justice (DOJ) intends to increase its efforts and devote additional resources to...more
In the latest sign that the federal enforcement apparatus is slowly but surely training its sights on white-collar professionals and businesses, particularly financial services, the Financial Crimes Enforcement Network...more
Under the Biden Administration, we expect the Department of Justice to reinvigorate the policies aimed at increasing coordination between the criminal and civil divisions. In a 2015 Memorandum – the “Yates Memo” – former...more
Learning objectives: - Governmental/Payor Data Analytics - Impact of Yates Memo and Data Analytics - COVID-19 Evaluation and Management Coding and Documentation - COVID-19 Testing Coding and Documentation -...more
Over the last twenty year (yes, 20 years), the Justice Department’s civil and criminal enforcement record has come under greater scrutiny. Whether you call it “Too Big To Jail” or “Too Big to Fail,” questions continue to...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 2015, then-Deputy AG Sally Yates (Attorney General Eric Holder’s second-in-command) published DOJ’s new policy statement on the investigation and prosecution of corporate offenses, heavily increasing focus on individuals...more
The Criminal Division of the United States Department of Justice (DOJ) recently released an update (April, 2019) to its Evaluation of Corporate Compliance Programs (Evaluation). The Evaluation was first introduced in 2017 to...more
Corporate compliance is increasingly becoming an important part of corporate culture and existence. However, there is a great deal of mystery around what compliance truly means, why it’s important, and what needs to be done...more
The U.S. Justice Department (DOJ) is still in the early days of applying a significant change to how companies get credit for cooperating during government investigations. In a speech delivered on November 29, 2018, Deputy...more
Despite predictions of a slow-down in enforcement under the Trump administration—and indications that enforcement in some areas has decreased in the past year1—2018 was yet again an active year for FCPA enforcement. The year...more
The January 2019 FCPA Digest is an invaluable compendium of all FCPA-related developments in 2018, including US foreign bribery proceedings and criminal prosecutions, DOJ foreign bribery civil actions, SEC actions, DOJ...more
INTRODUCTION: RECENT TRENDS AND PATTERNS IN FCPA ENFORCEMENT - Although FCPA enforcement across the 2018 calendar year seemed to ebb and flow, in retrospect the enforcement agencies brought a typical number of enforcement...more
In November, the U.S. Department of Justice revised principle 9-28.700 – The Value of Cooperation in its Justice Manual – aka the Yates Memo....more
On November 29, 2018, Deputy Attorney General Rod Rosenstein announced revisions to the Department of Justice (“DOJ”) policy on individual accountability for corporate wrongdoing, which was originally announced in the Yates...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
Harris Beach attorney Brian Mahoney presented a national webinar on “White-Collar Crime Enforcement: Legal Trends and Developments in 2017 and Beyond,” hosted by The Knowledge Group....more
Key Points: - DOJ is reviewing and reevaluating numerous corporate enforcement policies, including the “Yates Memo,” the FCPA Pilot Program, and policies on corporate monitors. - Policies will be codified in official...more
In a time of shifting opinions on the benefits of globalization, China’s “One Belt, One Road” initiative (OBOR) offers an unexpected bright spot for multinational companies able and willing to participate in this...more
The Justice Department’s continuing lack of individual criminal prosecutions in the FCPA arena continues to raise serious questions. DOJ’s issuance of the Yates memorandum was seen as a new and important reiteration of DOJ’s...more