Compliance Perspectives: Compliance Challenges in India
FCPA Compliance Report-Episode 350, Linda Justice and Her Nancy Drew Approach
Day 16 of One Month to More Effective Continuous Improvement-Voluntary Monitoring
Day 5 of One Month to Better Investigations and Reporting-the Board’s Investigation Protocol
On October 28, 2021, Deputy Attorney General Lisa Monaco announced revised Department of Justice (DOJ) guidance on corporate monitors. Going forward, prosecutors are free to require the imposition of a corporate monitor when...more
With the impact of COVID-19 increasing the likelihood of white collar crime, corporate vigilance and a quick response can mitigate downside consequences. There has been a notable uptick in white collar matters the past...more
In Episode 7 of Digging Deeper, Chris Morgan Jones and Darren Matthews explore how fraudsters find new avenues to take advantage of a business, and some cases where investigators cracked the code on bad actors....more
Jules Kroll is widely credited as the founder of the modern corporate investigations industry, and this episode goes behind the scenes of Jules’ career....more
What changes when an investigator leaves the public sector and joins the private sector? For Brian Cairl, senior managing director and director of investigations of the Americas, his toolkit from his time in law enforcement...more
What happens when an investigator stumbles upon a personal detail that leads to professional misdeeds? In Episode 3 of Digging Deeper, Chris Morgan Jones interviews Lisa Silverman, senior managing director in Chicago, about...more
As was true in many areas of the law, Foreign Corrupt Practices Act (FCPA) enforcement in 2020 - and anti-corruption enforcement more generally - was affected by the COVID-19 pandemic, but perhaps not as much as was initially...more
On January 17, 2020, the United Kingdom’s Serious Fraud Office (“SFO”) published new guidance regarding how the office assesses the compliance programs of organizations that are under investigation. “Evaluating a Compliance...more
On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more
The UK and the US signed a new data-sharing agreement on 3 October designed to facilitate the exchange of evidence and enhance co-operation between the two countries and their respective investigatory authorities. The first...more
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
In a recent decision that could have critical implications for corporate internal investigations conducted pursuant to a government agency’s request, the Southern District of New York expressed concern with the government’s...more
This latest installment of the Health Care Enforcement Quarterly Roundup reflects on trends that persisted in 2018 and those emerging trends that will carry us into 2019 and beyond. Leading off with the US Department of...more
Despite predictions of a slow-down in enforcement under the Trump administration—and indications that enforcement in some areas has decreased in the past year1—2018 was yet again an active year for FCPA enforcement. The year...more
On November 29, 2018, Deputy Attorney General Rod Rosenstein announced revisions to U.S. Department of Justice (DOJ) policies that expand prosecutors’ discretion in awarding cooperation credit to companies facing criminal or...more
In 2017, the U.S. Department of Justice (DOJ) initiated a review of its 2015 policy concerning individual accountability in corporate cases (known as the "Yates Memo"). In the course of that review, the DOJ considered...more
US Deputy Attorney General Rod J. Rosenstein recently announced that in every corporate investigation, the US Department of Justice will make it a top priority to pursue individuals responsible for corporate wrongdoing. This...more
One of the most insipid hit records of the 1960s was Roger Miller’s “England Swings (Like a Pendulum Do).” In an earlier edition of this august Journal, I detailed how differently our English “cousins” swing on the issue of...more
Responding to criticism stemming from a lack of individual prosecutions as a result of the financial crisis, Deputy Attorney General Sally Yates has issued a new guidance memorandum establishing six new steps for federal...more
On September 9, 2015, Deputy Attorney General Sally Quillian Yates introduced a new policy aimed at aggressively prosecuting individuals for white-collar crimes. A product of a DOJ working group that started under former...more
On September 9, 2015, Deputy Attorney General Sally Yates of the United States Department of Justice (“DOJ” or the “Department”) issued a new policy memorandum (the “Yates Memo”) entitled “Individual Accountability for...more