The much-heralded end to prosecutions brought pursuant to the Foreign Corrupt Practices Act (FCPA) never materialized during the first Donald Trump administration, but Trump 2.0 has the potential to bring major change to the...more
On 23 September 2024, the DOJ announced another significant round of updates to its Evaluation of Corporate Compliance Programs (ECCP) – the guidance document Department of Justice (DOJ) prosecutors use to evaluate the...more
9/27/2024
/ Artificial Intelligence ,
Compliance ,
Corporate Governance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Emerging Technologies ,
Enforcement Actions ,
Risk Assessment ,
Risk Management ,
Whistleblower Protection Policies ,
Whistleblowers
After months of anticipation, the Department of Justice (DOJ) unveiled the details of its new Corporate Whistleblower Awards Pilot Program (the Corporate WB Program or the Program)....more
8/8/2024
/ Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Employees ,
Federal Pilot Programs ,
Pilot Programs ,
Self-Reporting ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
On 28 February 2024, President Biden issued Executive Order 14117 of February 28, 2024, Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern (EO) aimed...more
3/25/2024
/ Biden Administration ,
Data Collection ,
Data Storage ,
Data Transfers ,
Data-Sharing ,
Department of Justice (DOJ) ,
Executive Orders ,
Foreign Entities ,
International Data Transfers ,
Personal Data ,
Regulatory Oversight
On 7 March 2024, the US Department of Justice (DOJ) announced that it is launching a new whistleblower pilot program designed to reward individuals who report acts of significant corporate misconduct or financial wrongdoing...more
On 4 October 2023, Deputy Attorney General (DAG) Lisa Monaco announced a new US Department of Justice (DOJ) Safe Harbor Policy for voluntary self-disclosure made in connection with mergers and acquisitions (M&A)....more
In a keynote address to the American Bar Association’s 2021 National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa O. Monaco outlined major changes to the U.S. Department of Justice’s (DOJ) priorities...more
In this episode, Investigations, Enforcement and White Collar partners Bobby Higdon and David Rybicki reflect on their recent posts in the Department of Justice and what to expect in the world of corporate enforcement under...more
In this second episode of our series on the government's response to the Paycheck Protection Program, white collar practitioners Chris Nasson, David Rybicki, Neil Smith, and Hayley Trahan-Liptak discuss the second phase of...more
This article analyzes emerging risks to PE firms that invest in the health care sector by examining the current enforcement landscape and significant FCA litigation; identifies key factors that increase FCA risk for PE firms...more
The long-anticipated wave of civil enforcement actions involving participants in the Paycheck Protection Program (PPP) has begun. On 12 January 2021, the U.S. Department of Justice (DOJ) announced the first civil settlement...more
Increased Foreign Agents Registration Act (FARA) enforcement is here to stay. That is the consensus view of senior Department of Justice (DOJ) officials responsible for the statute’s administration and enforcement who...more
As many corporate practitioners know from experience, U.S. Department of Justice (DOJ) lawyers and federal prosecutors often factor a company’s inability to pay into corporate civil and criminal resolutions with the...more
For the first time since 2014, the Department of Justice’s (DOJ) Foreign Corrupt Practices Act (FCPA) Unit has issued an opinion responding to a request for advice on compliance with the anti-bribery provisions of the FCPA. ...more
I. INTRODUCTION - On 1 June 2020, the Criminal Division of the U.S. Department of Justice (DOJ) updated a critical guidance document, the “Evaluation of Corporate Compliance Programs” memorandum (“Guidance”), providing...more