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
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
On November 25th, the OECD Council for Further Combating Bribery of Foreign Public Officials in International Business Transactions adopted a series of recommendations for member countries to implement, in an effort to curb...more
12/14/2021
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Compliance ,
Corruption ,
Foreign Corrupt Practices Act (FCPA) ,
Multinational Investigations ,
OECD ,
Popular ,
Public Officials ,
White Collar Crimes
On October 28, 2021, Deputy Attorney General (DAG) Lisa O. Monaco gave the keynote address at the ABA’s 36th National Institute on White Collar Crime and announced a series of changes in the Department of Justice’s (DOJ)...more
Aerospace, defense, and government services – tighter control ahead -
2020 was an eventful year for companies in the aerospace, defense, and government services (ADG) sector. The industry saw arguably the largest...more
In October, the World Bank Group (WBG) published its third Sanctions System Annual Report for Fiscal Year 2020 (FY20), which covers the period from 1 July 2019 to 30 June 2020. The report provides a detailed look at the...more
12/21/2020
/ Anti-Corruption ,
Cooperative Compliance Regime ,
Coronavirus/COVID-19 ,
Economic Sanctions ,
Financial Fraud ,
Infectious Diseases ,
Integrity Policies ,
Regulatory Violations ,
Suspensions & Debarments ,
White Collar Crimes ,
World Bank
This month’s analysis looks at individual prosecutions under the Foreign Corrupt Practices Act (FCPA). Prosecutions have markedly increased over the last five years, and this will better define local, regional, and...more
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
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
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
5/21/2019
/ Brazil ,
Bribery ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
FBI ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Kickbacks ,
Medical Devices ,
Multinationals ,
Pharmaceutical Industry ,
Popular ,
Price-Fixing ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
In a recent decision that could have critical implications for corporate internal investigations conducted pursuant to a government agency’s request, the Southern District of New York expressed concern with the government’s...more
5/8/2019
/ Anti-Manipulation Rule ,
CFTC ,
Cooperation Agreement ,
Corporate Investigations ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Deutsche Bank ,
Internal Investigations ,
Libor ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
Government attorneys now have additional discretion in False Claims Act (FCA) civil cases to award cooperation credit to a corporation that meaningfully assists the government’s investigation without necessarily identifying...more
12/4/2018
/ Cooperation Agreement ,
Corporate Crimes ,
Corporate Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Government Investigations ,
Policy Statement ,
Qui Tam ,
White Collar Crimes ,
Willful Misconduct ,
Yates Memorandum
When a legal team needs to find the facts behind fraud and corruption allegations in a government investigation, technology can drive substantial new efficiencies. ...more
A new plea bargaining system – offering reduced penalties to companies that report certain violations and cooperate with government investigations – will come into effect in Japan this June, reflecting an amendment to the...more