On March 3, 2023, as part of the rollout of several updates to its guidance on corporate compliance programs, the Department of Justice (DOJ) released a new policy aimed at incentivizing compliance-driven compensation and...more
3/6/2023
/ Chief Compliance Officers ,
Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
New Guidance ,
Risk Assessment ,
White Collar Crimes
On September 15, 2022, the Department of Justice (Department) released a memorandum revising several key aspects of its corporate criminal enforcement policies. The new policy, titled Further Revisions to Corporate Criminal...more
9/20/2022
/ Compliance ,
Compliance Monitoring ,
Cooperation ,
Corporate Crimes ,
Corporate Culture ,
Corporate Misconduct ,
Corporate Monitoring ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Personal Liability ,
Voluntary Disclosure ,
White Collar Crimes
On May 9, 2018, Deputy Attorney General Rod J. Rosenstein introduced a new Department of Justice (DOJ) Policy on Coordination of Corporate Resolution Penalties (the Policy) while speaking at the New York City Bar White Collar...more
On April 5, 2016, the Fraud Section of the Department of Justice's (DOJ) Criminal Division issued an enforcement plan and guidance (the Guidance) laying out three steps it is taking to intensify Foreign Corrupt Practices Act...more
4/11/2016
/ Compliance ,
Cooperation ,
Corporate Misconduct ,
Corruption ,
Criminal Prosecution ,
Declination ,
Department of Justice (DOJ) ,
Disgorgement ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Individual Accountability ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes
Busy Q1 Yields Several Significant FCPA Resolutions -
Overview -
On February 19, during the US Securities and Exchange Commission’s (SEC) annual “SEC Speaks” conference, Kara Brockmeyer, Chief of the SEC’s FCPA...more
3/25/2016
/ Anti-Bribery ,
Anti-Kickback Statute ,
Books & Records ,
Compliance ,
Cooperation ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Internal Controls ,
Misrepresentation ,
Qualcomm ,
Securities and Exchange Commission (SEC) ,
Transparency