DOJ recently announced white-collar crime enforcement priorities and significant changes to its corporate enforcement policies (here and here). “[O]verbroad and unchecked corporate and white-collar enforcement burdens U.S....more
On September 23, 2024, the Criminal Division of the U.S Department of Justice (“DOJ”) released revised Evaluation of Corporate Compliance Programs guidance (“September 2024 Guidance), last updated in March 2023....more
9/27/2024
/ Chief Compliance Officers ,
Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Guidance Update ,
Pilot Programs ,
Reporting Requirements ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
The U.S. Department of Justice’s (“DOJ”) Criminal Division announced its new Corporate Whistleblower Awards Pilot Program on August 1, 2024. The Pilot Program incentivizes whistleblowers to provide information to the DOJ so...more
8/8/2024
/ CFTC ,
Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Foreign Corrupt Practices Act (FCPA) ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Self-Reporting ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
In the U.S. Department of Justice’s (DOJ) latest policy in furtherance of its “carrots and sticks” approach to corporate criminal enforcement, senior leadership of its Criminal Division announced a new Pilot Program on...more
Last week, senior Department of Justice leadership announced new policies and programs intended to further its “carrot and sticks” approach to corporate criminal enforcement, which has borne fruit with twice as many voluntary...more
3/14/2024
/ Artificial Intelligence ,
CFTC ,
Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
FinCEN ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
As previously reported, the Department of Justice (DOJ) has announced comprehensive corporate criminal enforcement policy changes utilizing both “carrots” and “sticks” to encourage companies to voluntarily self-disclose...more
Over the last two years, the Department of Justice (DOJ) has announced numerous policy changes on corporate criminal enforcement policies, which were largely based on a self-described “carrot and sticks” approach (“a mix of...more
10/6/2023
/ Acquisitions ,
Antitrust Division ,
Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Misconduct ,
Declination ,
Department of Justice (DOJ) ,
Enforcement ,
Mergers ,
Policy Statement ,
Safe Harbors ,
Voluntary Disclosure
On February 22, 2023, the U.S. Department of Justice (DOJ) announced and implemented a new Voluntary Self-Disclosure Policy specific to the 93 United States Attorney’s Offices (USAOs) throughout the nation. Before...more
The Department of Justice (DOJ) has been touting revisions to its corporate criminal enforcement policies and signaling increased action for nearly a year. Yesterday, Deputy Attorney General Lisa O. Monaco formally announced...more
9/19/2022
/ Compliance ,
Corporate Counsel ,
Corporate Culture ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Foreign Corrupt Practices Act (FCPA) ,
Individual Accountability ,
Personal Liability ,
Voluntary Disclosure ,
White Collar Crimes
On March 3, 2022, at the 37th Annual American Bar Association Criminal Justice Section National Institute on White Collar Crime in San Francisco, Attorney General Merrick B. Garland emphasized that “the prosecution of...more
3/11/2022
/ Antitrust Violations ,
CARES Act ,
Centers for Medicare & Medicaid Services (CMS) ,
CFTC ,
Compliance ,
Corporate Misconduct ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Environmental Crimes ,
Foreign Corrupt Practices Act (FCPA) ,
IRS ,
Merrick Garland ,
Personal Liability ,
Securities Fraud ,
White Collar Crimes
At the 36th Annual American Bar Association National Institute on White Collar Conference on October 28, 2021, Deputy Attorney General Lisa Monaco announced significant changes to Department of Justice policies on corporate...more