News & Analysis as of

Cooperative Compliance Regime Department of Justice (DOJ)

Robinson & Cole LLP

Legal Update: Department of Justice National Security Division Announces First-of-Its-Kind Declination under Its Voluntary...

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On May 22, 2024, the Department of Justice (DOJ) announced the first-ever declination under the National Security Division’s recently updated Enforcement Policy for Business Organizations (NSD Policy). The NSD Policy offers...more

Polsinelli

"Please Pay No Attention to the Microphone:” DOJ Announces New Program Offering Protections to Criminal Whistleblowers

Polsinelli on

On April 15, 2024, the Criminal Division of the U.S. Department of Justice (“DOJ”) released new guidance relating to a Pilot Program on Voluntary Self-Disclosures for Individuals, promising to offer protection from criminal...more

Woods Rogers

Wax On, Wane Not: Corporate Investigations and Enforcement Actions are on the Rise at DOJ

Woods Rogers on

Every national election cycle, we are reminded that presidential administrations drive the trajectory of white-collar civil and criminal enforcement priorities. Halfway through President Biden’s first term, in 2022, Attorney...more

J.S. Held

INDEPTH FEATURE: Corporate Fraud & Corruption 2024

J.S. Held on

To what extent are boards and senior executives in your country of focus taking proactive steps to reduce incidences of fraud and corruption from surfacing within their company? Over the past several years, there has been...more

Ballard Spahr LLP

DOJ Launches Whistleblower Pilot Program and Cracks Down on AI Misuse

Ballard Spahr LLP on

The Department of Justice (DOJ) has unveiled a new whistleblower policy designed to incentivize individuals to disclose corporate misconduct through financial rewards from any resulting forfeiture of criminal proceeds. The...more

Thomas Fox - Compliance Evangelist

Using a Root Cause Analysis for Remediation

The 2023 ECCP re-emphasized the need for both performing a root cause analysis but equally importantly using it to remediate your compliance program. It stated, “a hallmark of a compliance program that is working effectively...more

Troutman Pepper

DOJ's New Voluntary Self-Disclosure Policy Raises More Questions Than It Answers

Troutman Pepper on

On February 22, 2023, the Department of Justice (DOJ) issued a press release highlighting the new Voluntary Self-Disclosure (VSD) Policy for U.S. Attorney’s Offices (USAOs). The DOJ developed this policy, which is applicable...more

J.S. Held

Building a Strong Compliance Program That Meets the Revised DOJ Corporate Enforcement Policy

J.S. Held on

A corporate compliance program can be thought of as a magnet that brings a company’s compliance efforts together. It is an operational program, not simply a code of expected ethical behavior. An effective compliance...more

The Volkov Law Group

DOJ Issues Revised Corporate Compliance Guidance: Consequence Management, Clawbacks and Human Resource Cooperation (Part I of III)

The Volkov Law Group on

The Justice Department is rapidly pushing corporations to a new level of compliance.  We are witnessing a watershed moment – DOJ is raising the bar on expectations surrounding corporate compliance programs.  It would be a...more

Robinson & Cole LLP

DOJ Announces Significant Corporate Compliance Initiatives

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The U.S. Department of Justice (DOJ) recently announced several new policies and programs aimed at incentivizing corporate compliance. These programs underscore the need for companies to investigate, mitigate and resolve...more

Conn Kavanaugh

“Corporate Citizen, Police Thyself”: How the DOJ Is Changing Its Corporate Enforcement Policy to Encourage Self-Policing

Conn Kavanaugh on

Self-Reporting Remains a Major Focus - Few executives expect to interact with the Department of Justice (DOJ) during their careers, but the current DOJ has given companies some homework, and the assignment applies to...more

Cooley LLP

Considering Texting About Work? Beware.

Cooley LLP on

As the rise in remote work has led to an increased reliance on mobile devices to stay connected – with cellphones at our fingertips virtually 24/7 – the use of third-party messaging applications to communicate about work has...more

Society of Corporate Compliance and Ethics...

CEP Magazine - December 2022. Good things happen when enforcement listens

CEP Magazine - December 2022 - In September, U.S. Department of Justice (DOJ) Deputy Attorney General Lisa O. Monaco announced new guidelines the department will use in connection with criminal enforcement. Those...more

Akerman LLP

Carrots and Sticks: DOJ Announces Policy Shift on Corporate Crime

Akerman LLP on

On September 15, Deputy Assistant General of the United States ("DAG") Lisa Monaco announced new U.S. Department of Justice ("DOJ") policy changes during a speech on corporate criminal enforcement at New York University Law...more

Dechert LLP

Measure Twice, Cut Once: New DOJ Compliance Certifications Put CEOs and CCOs at Risk of Individual Criminal Liability

Dechert LLP on

Key Takeaways - As DOJ senior leadership signaled it would do since March, DOJ has now officially required as part of resolving a corporate enforcement action, that a Chief Compliance Officer (CCO) and Chief Executive...more

The Volkov Law Group

DOJ CCO Certification Requirements and DOJ Compliance Mandates (Part II of III)

The Volkov Law Group on

The new DOJ Certification requirements certainly raise a number of new issues and risks for senior management and chief compliance officers.  In Part I of this series, I outlined the specific language and the Plea Agreement...more

The Volkov Law Group

DOJ Compliance Program Certification Requirements (Part I of III)

The Volkov Law Group on

The Department of Justice continues to respond to the compliance community’s concerns about the new certification requirement adopted as part of the Glencore FCPA enforcement action.  DOJ has adopted this new requirement to...more

Jenner & Block

DOJ Initiatives Aim to Empower Chief Compliance Officers and Strengthen Corporate Compliance Programs

Jenner & Block on

On March 25, 2022, Kenneth Polite, Assistant Attorney General for the Department of Justice (DOJ)’s Criminal Division, delivered a speech at NYU Law School’s Program on Corporate Compliance and Enforcement announcing...more

Jenner & Block

Anti-Corruption Enforcement - 2021 Year in Review

Jenner & Block on

Due to the impact of the COVID-19 pandemic, and the change in presidential administrations in the United States in January 2021, US enforcement of the Foreign Corrupt Practices Act (FCPA) declined in 2021. However, we...more

Jones Day

DOJ Announces Civil Cyber-Fraud Initiative

Jones Day on

The U.S. Department of Justice announces an initiative targeting cybersecurity-related fraud by government contractors and grant recipients. On October 6, 2021, the U.S. Department of Justice ("DOJ") announced a new Civil...more

The Volkov Law Group

DOJ and SEC Announce First Corporate FCPA Settlement for 2021: Amec Foster Wheeler, a Wood Group Subsidiary, Agrees to Pay over...

The Volkov Law Group on

The Justice Department and the Securities Exchange Commission are back in business.  The first corporate FCPA enforcement action in 2021 came after a six-month hiatus in 2021.  While many commentators sought to read the...more

Mitratech Holdings, Inc

Aligning Vendor Risk Management to US Department of Justice Expectations

In June 2020, the US Department of Justice Criminal Division (DOJ) released an updated “Evaluation of Corporate Compliance Programs” notification. Our (and maybe your) first reaction upon hearing of this doctrine was likely,...more

Mitratech Holdings, Inc

COVID Risk Events and DOJ Compliance Expectations

To say it’s a challenge might be an understatement: Many managers are wondering to what extent their regulators will allow them to modify compliance standards during COVID-19....more

Foodman CPAs & Advisors

¿Qué hay de nuevo en la Guía del “DOJ” de Evaluación del Programa de Cumplimiento Corporativo actualizada?

El 1 de junio de 2020, la División Criminal del Departamento de Justicia (“DOJ”) publicó una actualización de la Evaluación de Programas de Cumplimiento Corporativo de la División Criminal del Departamento de Justicia de los...more

Faegre Drinker Biddle & Reath LLP

Updated Criminal Division Guidelines for Compliance Programs

New guidelines from the Department of Justice (DOJ) Criminal Division emphasize that “individualized determinations” will drive the evaluation of corporate compliance programs. Announced June 1, 2020, these revisions also...more

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