Historically, successful white-collar prosecutions often turn on the government’s ability to identify “insiders” with firsthand knowledge of the alleged criminal scheme, who opt to cooperate with prosecutors in exchange for...more
8/7/2024
/ CFTC ,
Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
FinCEN ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements ,
Self-Reporting ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
Companies beware! The U.S. Department of Justice (DOJ) announced a pilot program “designed to encourage voluntary self-disclosure by individual participants in certain types of criminal conduct involving corporations.” In...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
On March 10, a U.S. Justice Department official announced that agency will continue its one-year Pilot Program, which was introduced by DOJ’s Fraud Section and set to expire on April 5 of this year. As we described in an...more
Enforcement of the Foreign Corrupt Practices Act (FCPA) remained a high priority for the Department of Justice and the Securities and Exchange Commission in 2016, resulting in more than 50 combined enforcement actions, record...more
2/8/2017
/ Books & Records ,
Chief Compliance Officers ,
Declination ,
Department of Justice (DOJ) ,
Disgorgement ,
Enforcement Actions ,
Enforcement Statistics ,
Federal Pilot Programs ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Subsidiaries ,
Securities and Exchange Commission (SEC) ,
Successor Liability ,
Voluntary Disclosure ,
Whistleblowers
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