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
Two recent Foreign Corrupt Practices Act (FCPA) actions – a Department of Justice (DOJ) Opinion letter and an SEC settlement – underscore key diligence questions that legal and compliance departments should address when...more
9/11/2023
/ Civil Monetary Penalty ,
Compliance ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Disgorgement ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Meal and Entertainment Expenditures ,
New Regulations ,
Opinion Letter ,
Pre-Judgment Interest ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Travel Expenses
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