“Call us before we call you.” With this message, on January 10, 2024, the Southern District of New York announced the SDNY Whistleblower Pilot Program (Pilot Program), which seeks to encourage individual participants in...more
1/25/2024
/ Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Non-Prosecution Agreements ,
Pilot Programs ,
Voluntary Disclosure ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
On October 4, 2023, US Deputy Attorney General (DAG) Lisa Monaco announced that the US Department of Justice (DOJ) is adopting a new Mergers & Acquisitions Safe Harbor Policy, incentivizing companies to voluntarily disclose...more
10/10/2023
/ Acquisitions ,
Antitrust Division ,
Compliance ,
Cooperation ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Due Diligence ,
Mergers ,
Policies and Procedures ,
Safe Harbors ,
Voluntary Disclosure
On January 17, 2023, Assistant Attorney General Kenneth A. Polite, Jr. (AAG Polite) announced changes to the Department of Justice’s (DOJ) FCPA Corporate Enforcement Policy (CEP). The CEP, which applies to all Criminal...more
1/25/2023
/ Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Misconduct ,
Criminal Prosecution ,
Declination ,
Department of Justice (DOJ) ,
Disgorgement ,
Enforcement Priorities ,
Forfeiture ,
Restitution ,
Voluntary Disclosure ,
White Collar Crimes
On September 15, 2022, Department of Justice (DOJ) Deputy Attorney General (Deputy AG) Lisa Monaco announced new guidance for the DOJ’s corporate enforcement policies, which is memorialized in the Memorandum on Further...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
11/2/2021
/ Compliance ,
Compliance Monitoring ,
Cooperation ,
Corporate Crimes ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Authority ,
Government Investigations ,
Individual Accountability ,
Non-Prosecution Agreements ,
Policy Statement ,
Professional Misconduct ,
White Collar Crimes ,
Yates Memorandum
On December 13, 2019, the US Department of Justice (DOJ) announced a revised Export Control and Sanctions Enforcement Policy for Business Organizations (Revised EC/S Policy), clarifying its prior guidance on voluntary...more
1/14/2020
/ Amended Regulation ,
Compliance ,
Cooperation ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Disgorgement ,
Economic Sanctions ,
Enforcement ,
Enforcement Actions ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Forfeiture ,
Remediation ,
Voluntary Disclosure
On November 20, 2019, the US Department of Justice (DOJ) announced the latest revisions to the Foreign Corrupt Practices Act Corporate Enforcement Policy (the Corporate Enforcement Policy). The revised language provides...more
12/3/2019
/ Amended Regulation ,
Chief Compliance Officers ,
Compliance ,
Cooperation ,
Corporate Counsel ,
Corporate Misconduct ,
Declination ,
Department of Justice (DOJ) ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
Remediation ,
Self-Disclosure Requirements
On May 2, a federal district court judge minced no words in castigating the Government for effectively “outsourcing” its investigation into whether a bank manipulated the London Inter-Bank Offered Rate (LIBOR) to the bank...more
5/15/2019
/ Banks ,
Coercion ,
Cooperation ,
Corporate Counsel ,
Fifth Amendment ,
Government Investigations ,
Internal Investigations ,
Libor ,
Motion for Relief ,
Outsourcing ,
Risk Management ,
Self-Incrimination
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