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DOJ sets forth new incentives for companies to self-disclose and cooperate

On January 17, 2023, the Department of Justice (DOJ) rolled out revisions to its Corporate Enforcement Policy (CEP) aimed at incentivizing companies to voluntarily self-disclose misconduct and to cooperate with government...more

DOJ announces white collar initiatives to pursue individuals and assist victims

The American Bar Association’s annual white collar crime conference is often a favorite place for the U.S. Department of Justice to announce new policies and programs, and this year’s meeting in San Francisco was no...more

DOJ issues rare FCPA advisory opinion regarding the extortion exception

On January 21, 2022, the Department of Justice (“DOJ”) issued a Foreign Corrupt Practices Act (“FCPA”) Opinion Procedure Release (the “OPR” or “OPR 22-01”) addressing the rarely discussed extortion exception to the FCPA’s...more

Joint focus by Biden Administration and Congress points towards enhanced anti-corruption efforts

There has been significant movement recently, by both the Biden Administration as well as Congress, to enhance the U.S. government’s ability to tackle corruption. This article provides a summary of those efforts and several...more

The U.S. Department of Justice updates roadmap to an effective compliance program

On June 1, 2020, the U.S. Department of Justice (DOJ), Criminal Division, updated its guidance on the “Evaluation of Corporate Compliance Programs,” providing increased clarity on some of the key questions prosecutors will...more

DOJ refines cooperation requirements of FCPA corporate enforcement policy

On November 20, 2019, the U.S. Department of Justice (DOJ) announced several subtle, but important, adjustments to its Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy. These recent changes relate to...more

U.S. and Brazilian Authorities Reportedly Cooperating in Investigation of Alleged Bribery and Price Fixing Related to Medical...

In a May 17, 2019 press report that has been widely distributed in Brazil and the United States, Brazilian Federal Prosecutor Marisa Ferrari confirmed that the U.S. Federal Bureau of Investigation (FBI), the U.S. Department...more

Updated DOJ Guidance Underscores Importance of Implementing a Truly Effective Corporate Compliance Program

New guidance issued by the U.S. Department of Justice (DOJ) is the latest confirmation of the importance of implementing a robust compliance program that is not simply well-designed, but also effective....more

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