News & Analysis as of

Cooperation Compliance Voluntary Disclosure

BakerHostetler

The DOJ Announces Administration’s Revised Corporate Enforcement Strategy

BakerHostetler on

On May 12, 2025, Matthew Galeotti, Head of the Department of Justice’s (DOJ) Criminal Division, unveiled a comprehensive white collar enforcement strategy titled “Focus, Fairness, and Efficiency in the Fight Against...more

Fenwick & West LLP

DOJ Announces Key Revisions to Corporate Enforcement and Voluntary Self-Disclosure Policy

Fenwick & West LLP on

On May 12, 2025, the Head of the Department of Justice’s (DOJ) Criminal Division, Matthew Galeotti, announced a new white collar enforcement plan in a memorandum entitled “Focus, Fairness, and Efficiency in the Fight Against...more

Bracewell LLP

The CFTC’s New Advisory on Self-Reporting, Cooperation and Remediation

Bracewell LLP on

In an advisory announced February 25, 2025, the Division of Enforcement of the Commodity Futures Trading Commission (CFTC or Commission) announced a new regime for assessing cooperation credit in determining fines in the...more

Society of Corporate Compliance and Ethics...

Understanding the Latest DOJ Changes to Corporate Prosecutions

On November 22, 2024, then Principal Deputy Assistant Attorney General Nicole Argentieri recapped the changes made during the Biden Administration in enforcement policies and announced a few new ones. To better understand...more

Husch Blackwell LLP

The Justice Insiders Podcast: Self-Disclosure, Cooperation, and the Hazards of Knowing Too Little

Husch Blackwell LLP on

Host Gregg N. Sofer welcomes Husch Blackwell partner Catherine Hanaway to the podcast to discuss the recent sentencing of Nishad Singh, a former key lieutenant of Sam Bankman-Fried, the cryptocurrency mogul responsible for...more

Holland & Knight LLP

Modificación del régimen sancionatorio ambiental en Colombia

Holland & Knight LLP on

Hay siete novedades relevantes que las empresas en Colombia deben tener en cuenta con ocasión de la sanción de la Ley 2387 del 25 de julio de 2024, que modifica el régimen sancionatorio ambiental contenido en la Ley 1333 de...more

Snell & Wilmer

The Department of Justice Offers Individual Corporate Wrongdoers a “Get Out of Jail Free Card” in New Voluntary Self-Disclosure...

Snell & Wilmer on

The Department of Justice’s Criminal Division (DOJ) recently announced a Pilot Program on Voluntary Self-Disclosures for Individuals (the Individual VSD Pilot Program or Pilot Program), which allows certain individuals...more

The Volkov Law Group

DOJ Heralds New Voluntary Self-Disclosure Program for Individuals

The Volkov Law Group on

On April 15, 2023 Nicole Argentieri, Principal Deputy Assistant Attorney General and the Head of the U.S. Department of Justice’s (“DOJ’s”) Criminal Division, announced a new voluntary self-disclosure program for individuals...more

Mintz

DOJ’s Criminal Division Announces Pilot Program on Voluntary Self-Disclosure for Individuals

Mintz on

Drawing on a carrot and stick approach, Department of Justice (“DOJ” or the “Department”) guidance in 2023 focused heavily on incentivizing companies to voluntarily self-disclose their misconduct. This guidance included the...more

Venable LLP

DOJ Announces Pilot Program for Individual Voluntary Self-Disclosures

Venable LLP on

On April 15, 2024, the Department of Justice (DOJ) criminal division announced a new pilot program designed to reward individuals with non-prosecution agreements (NPAs) who voluntarily self-disclose "actionable, original...more

Goodwin

In Continuing Efforts to Incentivize Self-Disclosures and Cooperation, DOJ Announces Pilot Program to Pay Criminal Whistleblowers

Goodwin on

Over the last few years, the U.S. Department of Justice (“DOJ”) has continuously announced significant policies and programs directed at encouraging and rewarding the timely reporting of corporate wrongdoing, incentivizing...more

Tucker Arensberg, P.C.

U.S. Department of Justice (DOJ) Provides Corporate Fraud Enforcement Update

Tucker Arensberg, P.C. on

During the American Bar Association’s 39th National Institute on White Collar Crime, the most senior executives of the DOJ (Attorney General Merrick B. Garland and Deputy Attorney General Lisa Monaco) delivered remarks...more

Thomas Fox - Compliance Evangelist

Self-Disclosure is Now the Key

The Department of Justice (DOJ) has been making significant strides in emphasizing the importance of voluntary self-disclosure in corporate enforcement cases, particularly in the realm of the Foreign Corrupt Practices Act...more

Mintz

EnforceMintz — DOJ’s Efforts in 2023 to Incentivize Voluntary Self-Disclosure

Mintz on

2023 was a very active one for Department of Justice (DOJ or the “Department”) guidance, and that guidance had one clear theme: DOJ wants companies to voluntarily self-disclose their misconduct. To incentivize...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2023 Developments and Predictions for 2024

WilmerHale on

Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more

The Volkov Law Group

BIS Announces Further Enhancements to Voluntary Self-Disclosure Process

The Volkov Law Group on

On January 16, 2024, the U.S Department of Commerce’s Bureau of Industry and Security (“BIS”) released a series of enhancements to its existing voluntary self disclosure (“VSD”) program, pursuant to which organizations...more

Eversheds Sutherland (US) LLP

SDNY announces new whistleblower program, continuing Justice’s push for self-disclosure

“Call us before we call you.” With this message, on January 10, 2024, the Southern District of New York announced the SDNY Whistleblower Pilot Program (Pilot Program), which seeks to encourage individual participants in...more

Holland & Knight LLP

"Call Us Before We Call You": SDNY Announces Pilot Whistleblower Program

Holland & Knight LLP on

The U.S. Attorney's Office for the Southern District of New York (SDNY) on Jan. 10, 2024, announced a Whistleblower Pilot Program (Program) that it is presenting as another "tool in [the SDNY's] toolkit" that could unearth...more

White & Case LLP

A View from Abroad: Unpacking DOJ’s M&A Safe Harbor Policy, Part II

White & Case LLP on

On October 4, 2023, United States Deputy Attorney General (DAG) Lisa Monaco announced a new Department of Justice (DOJ) Mergers & Acquisitions Safe Harbor policy that encourages companies to self-disclose criminal misconduct...more

WilmerHale

Criminal Indictment for Medicare Advantage Fraud

WilmerHale on

The U.S. Department of Justice (DOJ) recently announced a rare criminal indictment involving the Medicare Advantage program—a contrast from DOJ’s more typical use of its civil enforcement authority to pursue similar issues...more

Troutman Pepper Locke

The Stick and the Carrot: DOJ Continues to Eye Corporate Crimes, While Encouraging Prompt Self-Disclosures of Misconduct...

Troutman Pepper Locke on

On October 4, Deputy Attorney General (DAG) Lisa Monaco announced the Department of Justice’s (DOJ) new Safe Harbor Policy for voluntary self-disclosures made in connection with mergers and acquisitions (M&A). This policy is...more

Holland & Knight LLP

Safe Harbor Policy Bolsters Case for Strong Environmental Due Diligence in M&A Transactions

Holland & Knight LLP on

The U.S. Department of Justice (DOJ) in October delivered a clear message to companies involved in mergers and acquisitions (M&A) and their advisers: Acquiring companies will not be penalized for timely voluntary disclosure...more

American Conference Institute (ACI)

[Event] 40th International Conference on the FCPA - November 28th - 30th, National Harbor, MD

Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more

Parker Poe Adams & Bernstein LLP

Increased Importance of Corporate Compliance Rises With New Department of Justice Safe Harbor Policy

Compliance assessments can be a valuable tool during the mergers and acquisitions process, but the Department of Justice (DOJ) is incentivizing due diligence reviews under a newly announced policy. Deputy Attorney...more

Wilson Sonsini Goodrich & Rosati

DOJ Releases New M&A Safe Harbor Policy: Key Takeaways for Deal Makers, Corporate Executives, and In-House Counsel

On October 4, 2023, Deputy Attorney General (AG) Lisa Monaco announced the U.S. Department of Justice’s (DOJ’s) new Mergers & Acquisitions Safe Harbor Policy for acquirers that uncover wrongdoing at a target company. Deputy...more

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