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Criminal Division White Collar Enforcement Plan: Turning the Page, Not Writing a New Book

On May 12, the Head of the U.S. Department of Justice (DOJ) Criminal Division, Matthew Galeotti, delivered remarks at the Securities Industry and Financial Markets Association’s Anti-Money Laundering and Financial Crimes...more

Keep Calm and Carry On: Thoughts on Recent Orders on FCPA Enforcement

What in the world is happening with enforcement of the Foreign Corrupt Practices Act (FCPA)? And what does the recent executive order (EO) and Department of Justice (DOJ) guidance mean for U.S. and global companies? Our view...more

DOJ Criminal Division Announces New Voluntary Self-Disclosure Pilot Program for Individuals

On April 22, 2024, the Acting Assistant Attorney General for the Department of Justice (“DOJ”) Criminal Division (“Acting AAG”) Nicole M. Argentieri offered commentary in a blog post regarding the Criminal Division’s newest...more

Recent Whistleblower Activity Increases Pressure on Internal Reporting and Investigation Mechanisms

On May 5, 2023, the Securities and Exchange Commission (“SEC”) granted its largest-ever whistleblower award of $279M to an individual, reportedly stemming from Ericsson’s $1.1B settlement to resolve claims that the...more

Sign on the Dotted Line: Compliance Certifications by CEOs and CCOs A Likely Requirement

As it continues its focus not just on enforcement, but on compliance, members of the U.S. Department of Justice have foreshadowed a sea change for Chief Executive Officers and Chief Compliance Officers in corporate...more

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