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UK Government Publishes Guidance on the New ‘Failure to Prevent Fraud’ Offence

On 6 November 2024, the UK government published its guidance on the new ‘failure to prevent fraud’ offence, which was introduced in the Economic Crime and Corporate Transparency Act 2023 (ECCTA 2023).1 We covered the details...more

New ‘Failure To Prevent Fraud’ Offence Expected To Come Into Force in the UK Shortly

The UK government introduced a major overhaul of its framework for addressing financial crime — and brought into force numerous significant changes — when the Economic Crime and Corporate Transparency Act 2023 (the Act)...more

US Attorney for SDNY Launches Whistleblower Program To Encourage Self-Disclosure by Individuals

On January 10, 2024, Damian Williams, U.S. Attorney for the Southern District of New York (SDNY), announced the creation of that office’s Whistleblower Pilot Program (Program). This initiative provides notice of the...more

DOJ Focus on Corporate Enforcement Continues With Updated Policies Related to Corporate Crime and Compliance Programs

In early March 2023, the Department of Justice (DOJ) released several important updates to its policies related to corporate crime enforcement and compliance programs. We discuss below the following key topics: (i) The DOJ...more

DOJ Implements Voluntary Self-Disclosure Policy for US Attorneys’ Offices

On February 22, 2023, the Department of Justice (DOJ) adopted a new policy that establishes a national standard for voluntary self-disclosure credit in corporate criminal enforcement actions brought by U.S. Attorneys’ Offices...more

France Further Aligns Corporate Crime Guidance With US and UK Approaches to Sentencing and Leniency

On January 16, 2023, France’s financial prosecutor, the “Parquet National Financier” (PNF), issued updated guidance (the Guidelines) regarding its approach to offering, negotiating and entering into French deferred...more

Revisions to the DOJ’s Corporate Criminal Enforcement Policy Will Require Companies To Reevaluate Their Compliance Systems

In a recently published memorandum, Deputy Attorney General (DAG) Lisa Monaco announced important updates to the U.S. Department of Justice’s (DOJ’s) approach to investigating and prosecuting corporate crimes. In the...more

DOJ Reveals White Collar Crime Enforcement Priorities: Key Themes From the March 2022 ABA National Institute on White Collar Crime

Remarks made by U.S. Department of Justice (DOJ) officials at the March 2022 American Bar Association’s (ABA’s) National Institute on White Collar Crime (the White Collar Conference) reflect the DOJ’s prioritizing white...more

DOJ Compliance Program Guidance Shows Value of a Compliance Committee

Though directed at prosecutors, the June 1, 2020, guidance on corporate compliance programs (Guidance) from the U.S. Department of Justice (DOJ) is a source of practical advice for in-house legal and compliance teams in...more

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