In an executive order issued on February 10, 2025 (Executive Order), and a memorandum issued by Attorney General Pam Bondi regarding cartels and transnational criminal organizations on February 5, 2025 (Cartel Memo), the...more
2/17/2025
/ Anti-Corruption ,
Attorney General ,
Compliance ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Regulatory Reform ,
Trump Administration ,
White Collar Crimes
On August 1, 2024, the Department of Justice (DOJ) officially launched its three-year corporate whistleblower awards pilot program (Whistleblower Program), adding to the growing array of programs designed to incentivize...more
Just over a month after Deputy Attorney General Lisa Monaco announced the upcoming launch of the Department of Justice’s whistleblower rewards program, the DOJ Criminal Division unveiled its newest program to incentivize...more
5/13/2024
/ Corporate Crimes ,
Corporate Governance ,
Corporate Misconduct ,
Criminal Convictions ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Financial Crimes ,
Fraud ,
Investigations ,
Publicly-Traded Companies ,
Self-Disclosure Requirements ,
Voluntary Disclosure
The Department of Justice (DOJ) recently announced two new measures to enhance its corporate criminal enforcement efforts: a whistleblower rewards program and updated guidance under which federal prosecutors will assess risks...more
5/13/2024
/ Artificial Intelligence ,
Corporate Crimes ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Pilot Programs ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Whistleblowers ,
White Collar Crimes
Continuing to prioritize corporate criminal enforcement, the Department of Justice (DOJ) announced two new steps it is taking to identify potential corporate misconduct and evaluate companies’ compliance programs. Deputy...more
3/15/2024
/ Artificial Intelligence ,
CFTC ,
Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
FinCEN ,
Pilot Programs ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
On July 13, 2023, the White House published the National Strategy Implementation Plan (the Implementation Plan). According to the White House, the Implementation Plan is a “roadmap to realize” the mission of the National...more
On Friday, March 3, 2023, the Department of Justice (DOJ) Criminal Division released updated guidance regarding the “Evaluation of Corporate Compliance Programs.” Now in its fourth iteration, this guidance replaces the June...more
3/14/2023
/ Chief Compliance Officers ,
Clawbacks ,
Compliance ,
Corporate Misconduct ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Electronic Communications ,
Executive Compensation ,
Federal Pilot Programs ,
Guidance Update ,
Instant Messaging Apps ,
Mobile Devices ,
Policies and Procedures ,
White Collar Crimes
On March 1, 2023, the White House released a new National Cybersecurity Strategy (the Strategy) documenting the Biden-Harris administration’s approach to improving cybersecurity across the digital ecosystem. The Strategy...more
Last month, the Fraud Section, part of the US Department of Justice (DOJ) Criminal Division, released its annual year-in-review report. In this article, we highlight three key takeaways from the 2022 report....more
On February 22, 2023, the Department of Justice announced a new Voluntary Self-Disclosure Policy (the Disclosure Policy) that now governs corporate prosecutions by US Attorney’s Offices (USAOs) nationwide. Building on a 2022...more
3/1/2023
/ Cooperation ,
Corporate Governance ,
Corporate Misconduct ,
Corruption ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement ,
Federal Sentencing Guidelines ,
Policy Updates ,
Regulatory Agenda ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes
The Department of Justice (DOJ) has released its summary of False Claims Act (FCA) recoveries for Fiscal Year 2022. At $2.2 billion, financial recoveries were significantly lower than the $5.7 billion collected the year...more
On December 16, 2022, Attorney General Merrick Garland issued a memorandum announcing important revisions to the Department of Justice (DOJ)’s policies on charges, pleas, and sentencings. These revisions align DOJ’s policies...more
On January 17, 2023, Assistant Attorney General (AAG) Kenneth Polite, Jr., delivered a speech announcing several important revisions to the Department of Justice (DOJ) Criminal Division’s Corporate Enforcement Policy (CEP)...more
On September 15, 2022, Deputy Attorney General (DAG) Lisa Monaco issued a memorandum and delivered a speech, announcing several revisions to the Department of Justice's (DOJ)’s corporate criminal enforcement policies and...more
9/20/2022
/ Compliance ,
Corporate Counsel ,
Corporate Misconduct ,
Corruption ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Compensation ,
Government Officials ,
White Collar Crimes
On May 19, 2022, the Department of Justice (DOJ) issued revisions to its existing policy for charging offenses under the Computer Fraud and Abuse Act (CFAA) (2022 CFAA Policy). The revisions state that “good-faith” security...more
On March 25, 2022, Kenneth Polite, Assistant Attorney General for the Department of Justice (DOJ)’s Criminal Division, delivered a speech at NYU Law School’s Program on Corporate Compliance and Enforcement announcing...more
Due to the impact of the COVID-19 pandemic, and the change in presidential administrations in the United States in January 2021, US enforcement of the Foreign Corrupt Practices Act (FCPA) declined in 2021. However, we...more
1/19/2022
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Cooperative Compliance Regime ,
Corporate Culture ,
Corporate Liability ,
Corruption ,
Criminal Liability ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Securities and Exchange Commission (SEC) ,
UK ,
UK Bribery Act ,
White Collar Crimes
On October 28, 2021, Deputy Attorney General (DAG) Lisa Monaco delivered a speech and issued a memorandum announcing several important changes to the Department of Justice (DOJ)’s corporate criminal enforcement policies and...more
Ransomware attacks have become increasingly common and, according to the NSA Director, are projected to continue growing in prevalence. Amidst the rise in ransomware attacks, last week the United States Department of Justice...more
The Department of Justice (DOJ) announced this week a new Civil Cyber-Fraud initiative which will use the False Claims Act (FCA) to enforce government contract cybersecurity requirements. The initiative will be led by the...more