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Cooperation New Guidance Department of Justice (DOJ)

Fenwick & West LLP

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

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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

Holland & Knight LLP

DOJ Announces New Policies and Priorities in Prosecution of White Collar Crime

Holland & Knight LLP on

The U.S. Department of Justice (DOJ or Department) announced on May 12, 2025, new investigative and policy priorities, as well as changes to current DOJ guidance, that could have a significant impact on the prosecution of...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

WilmerHale

DOJ Announces Significant Guidance on Compliance, Compensation, Communications and Cooperation

WilmerHale on

On March 3, 2023, as part of the rollout of several updates to its guidance on corporate compliance programs, the Department of Justice (DOJ) released a new policy aimed at incentivizing compliance-driven compensation and...more

Venable LLP

Part 1: Cooperation in Government Investigations and Voluntary Self-Disclosure: What to Expect After DOJ’s Latest Guidance

Venable LLP on

​​​​​​​On September 15, Deputy Attorney General Lisa Monaco issued a department-wide memorandum containing revisions to the Justice Department’s (DOJ) corporate criminal enforcement policies (“the Memorandum”), including...more

Latham & Watkins LLP

US Deputy Attorney General Monaco Announces Revised Policies on Corporate Crime

Latham & Watkins LLP on

Updated DOJ policies will continue to focus on individual accountability and corporate recidivism, while aiming to provide additional incentives for voluntary self-reporting, foster greater transparency on use of monitors,...more

Eversheds Sutherland (US) LLP

The DOJ’s new guidance on corporate criminal enforcement - and what it means for your business

​​​​​​​On September 15, 2022, Department of Justice (DOJ) Deputy Attorney General (Deputy AG) Lisa Monaco announced new guidance for the DOJ’s corporate enforcement policies, which is memorialized in the Memorandum on Further...more

Holland & Knight LLP

New Administration: Expect More "Rigorous" Corporate Criminal Enforcement

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New Deputy Attorney General Lisa Monaco on October 28, 2021, previewed the U.S. Department of Justice's (DOJ) enhanced stance on corporate crime. Monaco announced the formation of a Corporate Crime Advisory Group, which will...more

Jones Day

DOJ Policy Increases Incentives for Self-Reporting of Potentially Willful Trade Violations

Jones Day on

The Situation: The U.S. Department of Justice ("DOJ") has issued guidance revising its 2016 voluntary disclosure policy to provide companies stronger incentives to voluntarily self-report apparent potentially willful trade...more

Faegre Drinker Biddle & Reath LLP

Important New Guidance for Companies Considering Voluntary Disclosures of Export Control and Sanctions Violations

On December 13, 2019, the U.S. Department of Justice’s National Security Division (NSD) issued important new policy guidance regarding voluntary disclosures of export control and sanctions laws violations. Among other things,...more

BCLP

DOJ Further Incentivizes Voluntary Disclosure with Small Changes to FCPA Corporate Enforcement Policy

BCLP on

The Department of Justice tweaked its FCPA Corporate Enforcement Policy to further incentivize corporations to make voluntary disclosures. These small changes essentially acknowledge that companies in a very early stage of an...more

Foley & Lardner LLP

DOJ Antitrust Division Announces New Policy to Incentivize Corporate Compliance

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The Department of Justice Antitrust Division will now consider a target company’s antitrust compliance program when determining how to resolve criminal matters. This represents a fundamental shift in the Antitrust Division’s...more

Latham & Watkins LLP

UK SFO Releases Guidance on Corporate Cooperation Credit

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Guidance sets out the SFO’s expectations for investigations but leaves open questions, particularly for cross-border investigations. On 6 August 2019, the UK Serious Fraud Office (SFO) issued its much-anticipated Corporate...more

BCLP

FCA Defendants and Counsel Beware: New DOJ Guidance on FCA Cooperation Credit May Leave Too Much to Prosecutors’ Discretion

BCLP on

In recent weeks, the United States Department of Justice (“DOJ”) published guidance in the Justice Manual at Section 4-4.112 on how it will award cooperation credit to entities and individuals that are being investigated for...more

Latham & Watkins LLP

New DOJ Guidance Increases Benefits for Robust Antitrust Compliance Programs - What Companies Need to Know

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The Antitrust Division’s new policy gives credit for pre-existing compliance programs, but only those that meet certain high standards. On July 11, 2019, Assistant Attorney General Makan Delrahim announced that the US...more

A&O Shearman

FINRA Releases New Guidance On Extraordinary Cooperation Credit

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On July 11, 2019, FINRA provided additional guidance on obtaining extraordinary cooperation credit to supplement its prior enforcement guidance. FINRA Regulatory Notice 19-23, FINRA Investigations: FINRA Supplements Prior...more

Wilson Sonsini Goodrich & Rosati

DOJ's Antitrust Division Announces New Policy Incentivizing Qualified Corporate Antitrust Compliance Programs

On July 11, 2019, Assistant Attorney General Makan Delrahim of the U.S. Department of Justice (DOJ) announced a new policy to incentivize corporate antitrust compliance. The DOJ will, for the first time, formally consider...more

Maynard Nexsen

Cooperation Credit in False Claims Act Defense and the Potential Impact of Reimbursement Analysis and Compliance

Maynard Nexsen on

While white collar and healthcare counsel have long known that one of the best strategies to reducing risk in defending a False Claims Act (FCA) case is cooperation and execution of compliance actions, the Department of...more

McDermott Will & Emery

DOJ Preserves Its Options in Cooperation Credit Guidance

McDermott Will & Emery on

DOJ recently announced the release of formal guidance on how civil attorneys can award “cooperation credit” to defendants who cooperate with DOJ during a False Claims Act investigation. This formal policy provides some new...more

Ruder Ware

The Federal Government Really Wants You to Self Disclose

Ruder Ware on

The Department of Justice (DOJ) along with other health care fraud enforcement agencies, continue to send strong signals that they want businesses to police themselves for potential compliance issues and self-disclose where...more

Bass, Berry & Sims PLC

Mixed Messages: DOJ Releases New FCA Cooperation Guidelines, while Study Questions Whether Cooperation Actually Garners Credit

Bass, Berry & Sims PLC on

The U.S. Department of Justice (DOJ) routinely encourages the subjects of False Claims Act (FCA) enforcement actions to make voluntary disclosures and fully cooperate with the government on the premise that cooperation leads...more

Harris Beach Murtha PLLC

DOJ Issues Guidelines for Cooperation Credit Specifically as to False Claims Act Matters

The United States Department of Justice (DOJ) has issued new guidelines regarding cooperation and credit for self-disclosure specifically in False Claims Act matters. Such guidelines provide an overview of factors to be...more

King & Spalding

DOJ Releases New Guidelines on Proactive Cooperation During FCA Investigations

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On May 7, 2019, the United States Department of Justice (DOJ) delivered new guidance on how potential False Claims Act (FCA) defendants can receive leniency in exchange for proactively disclosing misconduct and taking other...more

Foley & Lardner LLP

New DOJ Guidance on Cooperation in False Claims Act Cases

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On May 7, 2019, the Department of Justice (DOJ) released guidance for civil prosecutors in determining how to assess cooperation in False Claims Act (FCA) cases. See DOJ’s press release and its revised manual. In particular,...more

Perkins Coie

Getting Cooperation Credit Under New DOJ False Claims Act Guidance

Perkins Coie on

The U.S. Department of Justice (DOJ) released long awaited guidance last week on how it will evaluate and credit self-disclosures and cooperation in False Claims Act (FCA) cases. The new guidelines, codified in the DOJ’s...more

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