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The Volkov Law Group

John Deere Reaches $9.9 Million Settlement with SEC over FCPA Violations

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The U.S. Securities and Exchange Commission (“SEC”) recently instituted proceedings against Deere & Company (“John Deere”), a leading global manufacturer of agricultural and heavy machinery, for multiple violations of the...more

Holland & Hart LLP

Key Compliance Takeaways for Companies from the DOJ's New Corporate Whistleblower Program

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On August 1, 2024, the U.S. Department of Justice (“DOJ”) announced its new “Corporate Whistleblower Awards Pilot Program” (“DOJ Program”), a three-year initiative managed by DOJ’s Money Laundering and Asset Recovery Section....more

McDermott Will & Emery

DOJ Unveils Details of Corporate Whistleblower Awards Pilot Program

On August 1, 2024, the US Department of Justice’s (DOJ’s) Principal Deputy Assistant Attorney General of the Criminal Division, Nicole Argentieri, unveiled the highly anticipated details of DOJ’s Corporate Whistleblower...more

Hinch Newman LLP

First Case Where FTC Charges Company in Gig Economy With Violating the Business Opportunity Rule

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On July 2, 2024, the Federal Trade Commission announced that it is taking action against a gig work company for allegedly misleading consumers about the money they could make on the company’s platform and marketing its...more

Wilson Sonsini Goodrich & Rosati

National Security Division’s Voluntary Self-Disclosure Policy in Action: Exchanging Cooperation for Declination

Last month, the U.S. Department of Justice (DOJ) announced that it would not charge MilliporeSigma, a life sciences company, even though one of its employees falsified export documents. The DOJ declined to prosecute...more

White & Case LLP

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

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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

Axinn, Veltrop & Harkrider LLP

A New Port in a Storm: Comparing the M&A Safe-Harbor Policy With Leniency

DOJ’s announcement of a safe harbor for voluntary self-disclosure in the context of acquisitions is the latest policy change in support of its effort to incentivize compliance, empower compliance professionals, and make...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Announces Safe Harbor Policy for Voluntary Self-Disclosures Related to Mergers & Acquisitions

In the U.S. Department of Justice’s (DOJ’s) latest effort to promote voluntary self-disclosure of corporate misconduct by companies, Deputy Attorney General (DAG) Lisa Monaco has announced guidance regarding a new safe harbor...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Previews M&A-Focused Guidance on Voluntary Self-Disclosure of Corporate Misconduct

In recent remarks, Principal Associate Deputy Attorney General (PADAG) Marshall Miller of the Department of Justice (DOJ) revealed that Deputy Attorney General Lisa Monaco will soon announce new voluntary self-disclosure...more

A&O Shearman

Delaware Court Of Chancery Rejects Stockholder Demand For Corporation To Supplement Its Section 220 Production With Searches And...

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On August 25, 2023, Magistrate Bonnie W. David of the Delaware Chancery Court issued a post-trial report denying stockholder requests for supplemental productions of emails from Zendesk, Inc. (the “Company”) pursuant to a...more

Akin Gump Strauss Hauer & Feld LLP

Federal Agency Settlements with Wells Fargo Illustrate Sanctions Risks Involving IT Systems

Key Points - On March 30, 2023, OFAC announced a settlement agreement with Wells Fargo for 124 apparent violations of three different sanctions programs (Iran, Syria and Sudan), all related to a legacy Wachovia Bank...more

Paul Hastings LLP

A Commitment to Transparency: Clarifying Key Enhancements to the U.S. Department of Justice’s Corporate Enforcement Guidance

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Since September 2022, the U.S. Department of Justice (“DOJ” or “the Department”) has made a number of announcements signaling notable changes to its U.S. corporate enforcement policies. These changes include key revisions to...more

Akin Gump Strauss Hauer & Feld LLP

New DOJ Focus on Executive Compensation in Resolving Criminal Investigations

Key Points - The DOJ recently announced several policy updates tethering resolution of criminal investigations to a company’s compensation and bonus programs. These updates include executive compensation focused...more

Fox Rothschild LLP

DOJ Formalizes Framework for Corporate Cooperation Credit

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The Department of Justice (DOJ) announced a new voluntary self-disclosure policy February 22, 2023, that sets uniform criteria for how and when prosecutors should reward corporate cooperation in criminal investigations. The...more

NAVEX

The Justice Department Steps Up Its Compliance Message

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The U.S. Justice Department unveiled new policies about how it will prosecute cases of corporate misconduct, offering new incentives for companies whose misconduct includes “aggravating circumstances” to step forward and...more

WilmerHale

DOJ Announces Updates to Corporate Enforcement Policy

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Assistant Attorney General Kenneth A. Polite, Jr. Announces Changes to Department of Justice Criminal Division’s Corporate Enforcement Policy - On January 17, 2023, Assistant Attorney General for the Criminal Division...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

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance & Ethics Essentials Workshop - February 6th - 9th, 8:55 am - 3:30 pm CT

SCCE’s four-day Compliance & Ethics Essentials Workshop provides comprehensive education on the core elements of a compliance program. The curriculum is ideal for those new to or with little experience in compliance, as well...more

Cranfill Sumner LLP

DOJ Announces Revisions to Corporate Criminal Enforcement Policies

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Earlier this month, DOJ announced additional revisions to the Department’s existing policies and practices governing corporate criminal enforcement. Each of these revisions will soon find its way into DOJ’s Justice Manual....more

Foley Hoag LLP - White Collar Law &...

DOJ Updates Policies on Corporate Ethics and Compliance

Last week, Deputy Attorney General Lisa O. Monaco delivered remarks on corporate criminal enforcement, announcing revisions to DOJ’s policies for addressing corporate ethics and compliance matters. These changes reflect an...more

Jenner & Block

Deputy Attorney General Announces Revisions to DOJ's Corporate Criminal Enforcement Policies and Practices

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On September 15, 2022, Deputy Attorney General (DAG) Lisa Monaco issued a memorandum and delivered a speech, announcing several revisions to the Department of Justice's (DOJ)’s corporate criminal enforcement policies and...more

Ballard Spahr LLP

New DOJ Memo Includes Significant Changes to Corporate Crime Policies

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Summary - A new memorandum from Deputy Attorney General Lisa Monaco, released on September 15 (Memorandum), represents one of the most comprehensive updates in years to the approach of the U.S. Department of Justice (DOJ) in...more

Katten Muchin Rosenman LLP

Deputy Attorney General Monaco Reiterates DOJ's Focus on Prosecuting Individuals and Announces New Guidelines for Prosecuting...

On September 15, Deputy Attorney General (DAG) Lisa O. Monaco announced changes to the Department of Justice’s (DOJ) Corporate Criminal Enforcement program. In her speech, DAG Monaco emphasized DOJ’s commitment to prosecuting...more

Womble Bond Dickinson

DOJ Announcements on Corporate Criminal Enforcement: Defining the Carrots and Sticks

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The Department of Justice (DOJ) has been touting revisions to its corporate criminal enforcement policies and signaling increased action for nearly a year. Yesterday, Deputy Attorney General Lisa O. Monaco formally announced...more

Alston & Bird

Second Circuit Presents U.S. Companies Historic Opportunity to Defend Against FCPA Liability

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The Second Circuit has made the government’s formerly straightforward task of assigning vicarious liability to a corporate principal under the Foreign Corrupt Practices Act considerably harder. Our White Collar, Government &...more

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