The Department of Justice tweaked its FCPA Corporate Enforcement Policy to further incentivize corporations to make voluntary disclosures. These small changes essentially acknowledge that companies in a very early stage of an...more
In recent weeks, the United States Department of Justice (“DOJ”) published guidance in the Justice Manual at Section 4-4.112 on how it will award cooperation credit to entities and individuals that are being investigated for...more
7/29/2019
/ Chief Compliance Officers ,
Compliance ,
Cooperation ,
Corporate Counsel ,
Corporate Liability ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Federal Contractors ,
Government Investigations ,
New Guidance ,
Remedial Actions ,
Subsequent Remedial Measures ,
Voluntary Disclosure Agreement
When DOJ announced its FCPA Corporate Enforcement Policy in 2017 (later expanded to all corporate criminal defendants), defense lawyers expressed concern about a provision buried within what it meant to provide “timely and...more
Anti-Corruption enforcement remained a top priority in France, the UK, and the US in 2018. Join our firm's Global Anti-Corruption Team as they explain and analyze these three countries' anti-corruption enforcement efforts and...more
12/20/2018
/ Alstom ,
Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Chief Compliance Officers ,
Civil Monetary Penalty ,
Compliance ,
Cooperation ,
Corruption ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
France ,
KBR (formerly Kellogg Brown & Root) ,
Petrobras ,
Risk Management ,
Siemens ,
Teva Pharmaceuticals ,
UK ,
Voluntary Disclosure ,
White Collar Crimes
On November 29, 2018, Deputy Attorney General Rod Rosenstein announced changes to the Department of Justice’s policy concerning individual accountability in corporate cases, stating that “pursuing individuals responsible for...more
Enforcement of the Foreign Corrupt Practices Act was a high priority for the Department of Justice and the Securities and Exchange Commission in 2016. There's interest in how the new administration could impact enforcement as...more
6/16/2017
/ Alstom ,
Compliance ,
Cooperation ,
Enforcement Actions ,
Enforcement Statistics ,
Federal Pilot Programs ,
Foreign Corrupt Practices Act (FCPA) ,
Halliburton ,
KBR (formerly Kellogg Brown & Root) ,
Popular ,
Siemens ,
Teva Pharmaceuticals ,
Trump Administration ,
Voluntary Disclosure
Breaking new ground, the Department of Justice (DOJ) recently issued two “declinations with disgorgement” to two companies accused of Foreign Corrupt Practices Act (FCPA) violations. These declinations, released under the...more
For the next year, the Justice Department may be offering up to a 50% discount on fines imposed in FCPA cases. Yesterday, the U.S. Department of Justice’s (“DOJ”) Criminal Division announced the launch of a one-year pilot...more
4/7/2016
/ Compliance ,
Cooperation ,
Corporate Counsel ,
Corporate Misconduct ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Individual Accountability ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes
On February 16, 2016, the SEC announced its first ever deferred prosecution agreement (“DPA”) with an individual in a Foreign Corrupt Practices Act (“FCPA”) case. As part of a settlement in which a Massachusetts-based...more