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Clearer Carrots and More Restrained Sticks: Key Updates to DOJ Corporate Enforcement Policies

“The Criminal Division is turning a new page on white-collar and corporate enforcement.” So pronounced the head of the US Department of Justice (DOJ) Criminal Division, Matthew Galeotti, in a recent speech rolling out several...more

President Trump Orders FCPA Freeze; DOJ Announces Major Policy Realignment De-Emphasizing Corporate Investigations and Enforcement

The much-heralded end to prosecutions brought pursuant to the Foreign Corrupt Practices Act (FCPA) never materialized during the first Donald Trump administration, but Trump 2.0 has the potential to bring major change to the...more

Asset Management Regulatory Year in Review 2024

2024 was a year of meaningful regulatory change for asset managers globally. The regulatory activity was wide ranging and without a particular unifying theme. In fact, the wide, and in cases diverging focuses of key global...more

AI, Whistleblowers, and Data Analytics - Updated DOJ Compliance Guidance

On 23 September 2024, the DOJ announced another significant round of updates to its Evaluation of Corporate Compliance Programs (ECCP) – the guidance document Department of Justice (DOJ) prosecutors use to evaluate the...more

Department of Justice Launches First-Of-Its-Kind Corporate Whistleblower Awards Program

After months of anticipation, the Department of Justice (DOJ) unveiled the details of its new Corporate Whistleblower Awards Pilot Program (the Corporate WB Program or the Program)....more

Jarkesy's Impact on Agency Enforcement Proceedings: Potential Implications for the SEC and Beyond

On 27 June 2024, in a ruling much-anticipated by the securities industry and other similarly regulated industries, the Supreme Court (the Court) held in SEC v. Jarkesy that when the Securities and Exchange Commission (SEC)...more

Dialing for Dollars: US Department of Justice Announces New Whistleblower Pilot Program

On 7 March 2024, the US Department of Justice (DOJ) announced that it is launching a new whistleblower pilot program designed to reward individuals who report acts of significant corporate misconduct or financial wrongdoing...more

Criminalizing the "Quo:" The New Foreign Extortion Prevention Act Targets the Demand Side of Bribery

INTRODUCTION - On 22 December 2023, President Biden signed into law the National Defense Authorization Act (NDAA), the annual defense spending bill for 2024. Buried hundreds of pages into the NDAA is the new Foreign Extortion...more

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