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
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
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
On September 9, 2015, then U.S. Deputy Attorney General Sally Quillian Yates issued a memo, “Individual Accountability for Corporate Wrongdoing,” that sent shivers down the spines of those in the workplace safety community....more
As a product of the Department of Justice’s newly minted Corporate Crime Advisory Group, the DOJ has issued follow-up guidance to its October 2021 memo on corporate criminal enforcement, which reinstated prior guidance...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 November 29, 2021, we posted that the U.S. Department of Justice (DOJ) had recently reinstated the Yates memo, a 2015 enforcement policy memorandum that had been rescinded by the Trump Administration. The Yates memo...more
Criminal enforcement of environmental laws is a rarity, despite relatively light evidentiary intent standards. Blatant and unquestionably deliberate violations—the "secret pipe" type—are usually the only ones we see...more
In a speech to the ABA’s 2021 annual National Institute on White Collar Crime, Deputy Attorney General (“DAG”) Lisa Monaco emphasized that prosecuting individuals accused of white collar crime is a top priority for the Biden...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
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
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
In 2015, our colleagues in the white-collar criminal defense bar braced for the impact of a memorandum penned by then Deputy Attorney General Sally Yates. The Yates Memo encouraged both federal prosecutors and civil...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
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
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
by Jessica K. Nall and Janice W. Reicher[1] As the world watches the political and legal battles between the U.S. government and Chinese telecom giant Huawei unfold in the headlines, many are asking how the controversy may...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