The Department of Justice has announced yet another pilot program, adding to their “mix of carrots and sticks” designed “to promote responsible corporate citizenship.” The new whistleblower pilot program, which is still under...more
3/25/2024
/ Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Corruption ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Extortion ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
“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 February 22, 2023, the US Department of Justice issued a nationwide policy for all US Attorney’s Offices (USAOs) outlining the circumstances in which a company may receive credit for voluntary self-disclosure (VSD)....more
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
Our quarterly Financial Crime Horizon Scanner for the UK summarizes key financial crime related legal and regulatory changes expected over the next 2 years and provides electronic links to key resources.
We hope that you...more
5/2/2022
/ AML/CFT ,
Belarus ,
Consultation ,
Corporate Misconduct ,
Cyber Crimes ,
Due Diligence ,
Economic Sanctions ,
European Banking Authority (EBA) ,
FATF ,
Financial Crimes ,
Real Estate Development ,
Russia ,
UK
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
The US Department of Justice (DOJ) is increasingly using the money laundering statute to prosecute individuals in corruption and bribery cases. The Foreign Corrupt Practices Act (FCPA) is the primary statute prohibiting...more
11/12/2019
/ Alstom ,
Bribery ,
Corporate Misconduct ,
Criminal Conspiracy ,
Department of Justice (DOJ) ,
Equador ,
Extortion ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Forfeiture ,
Indictments ,
Money Laundering ,
Money Laundering Control Act (MLCA) of 1986 ,
Venezuela ,
Willful Misconduct
Last week, the US Department of Justice (DOJ) released its updated guidance on how prosecutors should evaluate corporate compliance programs. The revised guidance reiterates and expands on the hallmarks of successful...more