The Advisory sets out factors that the Enforcement Division will use to rate self-reporting and cooperation. This rating places a company or individual within a “tier” used to determine the Mitigation Credit amount available....more
The ECCP is intended to assist federal prosecutors in determining whether a corporation’s compliance program was effective at the time of the alleged offense(s) and, if not, what type of enforcement, monetary penalty, and...more
Designed for busy in-house counsel and compliance professionals, this newsletter seeks to bring you up to speed on key federal and state False Claims Act (FCA) developments, with links to primary resources. Each quarter, we...more
1/4/2024
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On March 3, 2023, the Criminal Division of the U.S. Department of Justice ("DOJ") revised its Evaluation of Corporate Compliance Programs or ECCP (the “March 2023 ECCP”) for the first time since June 2020....more
Speaking at a Compliance Week event on May 17, 2022, Assistant Attorney General (“AAG”) Kenneth Polite reaffirmed that companies that “take compliance seriously” can expect a reduced likelihood that investigators will impose...more
The Department of Justice (“DOJ” or “Department”) has continued to make clear that white collar crime is a top priority of its enforcement efforts. On October 28, 2021, Deputy Attorney General (“DAG”) Lisa Monaco issued a...more