News & Analysis as of

Cooperation Securities and Exchange Commission (SEC) Federal Pilot Programs

Holland & Knight LLP

Do You Hear What I Hear? DOJ, SEC Continue Promoting Merits of Self-Reporting in 2024

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2024 saw no change in the government's campaign to encourage self-reporting and cooperation. In the second installment of Season's Readings, we take a quick look at how the SEC treats self-reporting and how that differs...more

WilmerHale

DOJ Rolls Out Corporate Whistleblower Pilot Program

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On August 1, 2024, the Department of Justice officially launched a three-year pilot program to reward whistleblowers who report corporate misconduct....more

BakerHostetler

DOJ to Corporations - “Knock on Our Door Before We Knock on Yours”

BakerHostetler on

At last week’s ABA National White Collar Crime Institute, the leadership of the Department of Justice (the DOJ or the Department), including Attorney General Merrick Garland and Deputy Attorney General Lisa Monaco, made clear...more

Saul Ewing LLP

Happy Birthday FCPA: Implications of DOJ’s New FCPA Corporate Enforcement Policy on the Act’s 40th Anniversary

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Today being the fortieth anniversary of the December 19, 1977 enactment of the Foreign Corrupt Practices Act (“FCPA”), we offer this Client Alert in celebration of the occasion. Fittingly, the U.S. Department of Justice...more

WilmerHale

DOJ Announces New FCPA Corporate Enforcement Policy

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On November 29, 2017, “[d]ue to the unique issues presented in FCPA matters,” Deputy Attorney General Rod Rosenstein announced a new FCPA corporate enforcement policy published in a revision to the United States Attorneys'...more

Kilpatrick

3 Key Takeaways: Foreign Corrupt Practices Act Trends in 2017

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Kilpatrick Townsend partner Adria Perez recently presented to the Association of Corporate Counsel (ACC) Georgia Chapter about key 2017 trends concerning the enforcement of Foreign Corrupt Practices Act (“FCPA”) against...more

Bass, Berry & Sims PLC

FCPA: 2016 Year in Review & 2017 Enforcement Predictions

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Bass, Berry & Sims announces the release of its "FCPA: 2016 Year in Review & 2017 Enforcement Predictions," a review of trends and developments in FCPA as well as a look ahead into what to expect for 2017. The newly released...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2016 Developments and Predictions for 2017

WilmerHale on

The past year was consequential for FCPA enforcement in numerous respects, including blockbuster penalties, new policy initiatives, and the SEC’s first DPA with an individual for FCPA violations. In April 2016, the DOJ’s...more

Thomas Fox - Compliance Evangelist

General Cable FCPA Enforcement Action – Part II: The Comeback

Yesterday I began an exploration of the General Cable Corporation (General Cable) Foreign Corrupt Practices Act (FCPA) enforcement action. It was settled with the DOJ via a Non-Prosecution Agreement (NPA) and the SEC via a...more

Thomas Fox - Compliance Evangelist

FCPA Enforcement Going Forward in the Trump Administration

Donald Trump has gone on the record as saying the Foreign Corrupt Practices Act (FCPA) is a “horrible law and it should be changed” and that it puts US businesses at a “huge disadvantage.” This statement was made in the...more

Thomas Fox - Compliance Evangelist

When Leslie Caldwell Talks FCPA, You Should Listen

November begins the final push for the compliance conference season, which customarily ends with the ACI National FCPA Conference. During November and into early December, Department of Justice (DOJ) officials have...more

Troutman Pepper Locke

Lessons Learned from the FCPA Pilot Program's First Six Months

Troutman Pepper Locke on

The guidance issued by the DOJ in connection with the Pilot Program and recent declinations state that disclosure, remediation and cooperation are essential to any favorable resolution with the government. Six months...more

Thomas Fox - Compliance Evangelist

How to garner a NPA and Declination: Akamai and Nortek – Part I

It certainly did not take long for companies to see the benefit of the Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) Pilot Program around FCPA enforcement as this week there where two public declinations...more

Foster Garvey PC

DOJ’s New FCPA “Pilot Program” Targets Corporate Officers and Other Individuals

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For years, FCPA observers have predicted that the Department of Justice (“DOJ”) will increase its prosecutions of corporate officers and employees for FCPA violations. These predictions have so far proven disputable, as the...more

Dorsey & Whitney LLP

Dorsey Anti-Corruption Digest - April 2016

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Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more

Clark Hill PLC

DOJ's New FCPA Guidance and Pilot Program

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On April 5, 2016, in an effort to bolster FCPA Compliance, the Department of Justice issued its "Foreign Corrupt Practices Act Enforcement Plan and Guidance" identifying the following three steps to enhance its FCPA...more

Miller Canfield

DOJ’s Fraud Section Issues Foreign Corrupt Practices Act Enforcement Plan and Guidance

Miller Canfield on

On April 5, 2016, the Department of Justice’s Fraud Section (“DOJ”) issued its Foreign Corrupt Practices Act (“FCPA”) Enforcement Plan and Guidance (“Guidance”), which announced (1) a more than doubling of DOJ resources...more

Dorsey & Whitney LLP

DOJ’s New FCPA Pilot Program: The Offer of Enhanced Credit

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DOJ’s continuing focus on individuals has spawned a new one year FCPA Pilot Program which offers companies enhanced cooperation credit The new Pilot Program is part of an overall effort to bolster FCPA compliance. Those...more

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