On February 22, 2023, the United States Attorneys’ Offices (USAO) issued a new Voluntary Self-Disclosure (VSD) Policy, which is effective immediately. The policy follows the revisions announced last month to the Department of...more
Executive Summary: The most important Park doctrine case in over forty years may be heading to the Supreme Court – but not if the federal government has its way. The Responsible Corporate Officer doctrine (“RCO doctrine”),...more
5/4/2017
/ Corporate Misconduct ,
Corporate Officers ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Federal Food Drug and Cosmetic Act (FFDCA) ,
Food Contamination ,
Medical Devices ,
Misbranding ,
Negligence ,
Park Doctrine ,
Pharmaceutical Industry ,
Prescription Drugs ,
Responsible Corporate Officer Doctrine ,
Salmonella ,
SCOTUS ,
White Collar Crimes
Even before President Trump’s nomination of Jay Clayton as the next Chairman of the Securities and Exchange Commission (“SEC” or “Commission”), signs have been appearing that changes are afoot within the Division of...more
3/7/2017
/ Administrative Appointments ,
Anti-Bribery ,
Anti-Corruption ,
Deregulation ,
Dodd-Frank ,
Enforcement Actions ,
Executive Orders ,
Financial Institutions ,
Financial Markets ,
Financial Services Industry ,
Foreign Corrupt Practices Act (FCPA) ,
Proposed Legislation ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC) ,
Trump Administration
After a conventional presidential campaign, determining the policy priorities and direction of the incoming administration with respect to the Justice Department’s white collar law enforcement responsibilities can be a...more
11/30/2016
/ Affordable Care Act ,
Anti-Bribery ,
Bribery ,
BSA/AML ,
Corruption ,
Cybersecurity ,
Decriminalization of Marijuana ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Controls ,
False Claims Act (FCA) ,
FBI ,
Foreign Corrupt Practices Act (FCPA) ,
Generic Drugs ,
Healthcare ,
Healthcare Fraud ,
Medical Marijuana ,
National Security ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Pharmaceutical Industry ,
Popular ,
Prescription Drugs ,
Regulatory Oversight ,
RICO ,
Securities and Exchange Commission (SEC) ,
Surveillance ,
White Collar Crimes
On September 9, 2015, the U.S. Department of Justice announced a new policy regarding individual accountability for corporate misconduct. The policy, described in a memo authored by Deputy Attorney General Sally Yates,...more