News & Analysis as of

Yates Memorandum Foreign Corrupt Practices Act (FCPA)

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

HaystackID

Cooperation Standards in Government Investigations: Practical Tips

HaystackID on

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

Thomas Fox - Compliance Evangelist

FCPA Compliance Report - James Koukios on the Monaco Speech

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

Thomas Fox - Compliance Evangelist

Compliance Into The Weeds: DAG Announces Changes in Enforcement Priorities

Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Today, Matt and I have a rare emergency podcast on...more

Butler Snow LLP

DOJ’s Yates Memorandum 5 Years Down the Road: Alive but is it Kicking? FCPA Enforcement of Individuals Post-“Yates”

Butler Snow LLP on

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

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Emphasizes Transparency and Encourages Cooperation

In 2019, the Criminal Division of the U.S. Department of Justice (DOJ) continued its efforts, begun a few years prior, to enhance transparency with respect to the DOJ's prosecutorial decision-making. In public statements, DOJ...more

Skadden, Arps, Slate, Meagher & Flom LLP

Transatlantic Approach on Corporate Cooperation: How Newly Issued French and UK Guidance Compare to US Practices

As widely anticipated, French and U.K. regulators recently published guidance detailing their expectations for corporate cooperation in enforcement investigations. Both sets of guidance demonstrate further alignment of those...more

WilmerHale

Foreign Corrupt Practices Act Alert: Global Anti-Bribery Year-in-Review: 2018 Developments and Predictions for 2019

WilmerHale on

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

Skadden, Arps, Slate, Meagher & Flom LLP

Cross-Border Investigations Update - January 2019

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including DOJ guidance on the use of corporate monitors in criminal...more

A&O Shearman

FCPA Digest 2019 – Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act

A&O Shearman on

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

A&O Shearman

FCPA Digest - Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act - January 2019

A&O Shearman on

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

Morrison & Foerster LLP - Government...

Top 10 International Anti-Corruption Developments for November 2018

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

NAVEX

Action Not Perfection: DOJ Revisions to Yates Memo Still Prioritize Individual Accountability

NAVEX on

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

Downs Rachlin Martin PLLC

DOJ Announces Policy Changes On Corporate Cooperation In Both Criminal And Civil Cases

On November 29, 2018, during a speech at the International Conference on the Foreign Corrupt Practices Act, U.S. Deputy Attorney General Rod Rosenstein announced changes to the Department of Justice’s (DOJ or the Department)...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Announces Revisions to Yates Memorandum Policy

On November 29, 2018, in a speech at the 35th International Conference on the Foreign Corrupt Practices Act, U.S. Deputy Attorney General Rod Rosenstein announced the Department of Justice’s (DOJ or the Department) revised...more

Thomas Fox - Compliance Evangelist

Farewell to President Bush and Modification of the Yates Memo

During this week, I have been considering last week’s Department of Justice (DOJ) and Securities and Exchange Commission (SEC) pronouncements about where 2018 Foreign Corrupt Practices Act (FCPA) enforcements have been and...more

WilmerHale

DOJ Announces Revisions to Policy on Corporate Cooperation

WilmerHale on

In a November 29, 2018 speech, Deputy Attorney General Rod Rosenstein announced a softening of the US Department of Justice’s (DOJ) policy on giving credit for cooperation in corporate prosecutions. As memorialized in the...more

A&O Shearman

DOJ Scales Back Yates Memo Policy For Corporate Cooperation

A&O Shearman on

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

Kramer Levin Naftalis & Frankel LLP

DOJ Announces More Lenient Corporate Cooperation Policy

In a speech delivered on Thursday, Nov. 29, 2018, Deputy Attorney General Rod Rosenstein described important changes to DOJ policies for awarding cooperation credit in corporate investigations. These changes have been...more

BCLP

In announcing changes to individual accountability policy, DOJ reaffirms that cooperating companies must name responsible...

BCLP on

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

Pillsbury Winthrop Shaw Pittman LLP

DOJ Modifies White-Collar Policy Targeting Individuals

Speaking at FCPA event, Rosenstein sets out adjustments to Yates Memo. DOJ is modifying its focus on individual accountability in government investigations to substantially culpable individuals....more

Eversheds Sutherland (US) LLP

US Department of Justice relaxes Yates Memorandum’s requirements for earning cooperation credit

On November 29, 2018, the US Department of Justice (DOJ) modified prior guidance on individual liability for corporate misconduct by affording federal prosecutors discretion to focus on “individuals who play significant roles...more

Holland & Knight LLP

“Yates Memo” Edited to Grant Prosecutors More Flexibility in Civil Cases

Holland & Knight LLP on

On Sept. 9, 2015, then-Deputy Attorney General Sally Yates issued a memo requiring federal prosecutors to investigate any individuals responsible for illegal corporate conduct before settling a case. This applied to both...more

Farella Braun + Martel LLP

Battling Government Investigations Series – Cooperation and Voluntary Disclosure

It always comes when you least expect it – a government inquiry to investigate your business. While it may instill a sense of panic, there are steps you can take to make sure you’re in the best position possible when the...more

Harris Beach PLLC

Brian Mahoney Presents on White Collar Crime Enforcement Legal Trends

Harris Beach PLLC on

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

103 Results
 / 
View per page
Page: of 5

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide