News & Analysis as of

Corporate Misconduct Enforcement Actions

The Volkov Law Group

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

The Volkov Law Group on

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

The Volkov Law Group

DOJ Awards Declination to Proterial Cable America for Fraud — Proterial Pays $15.1 Million in Disgorgement

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DOJ is pushing hard for voluntary disclosures and urging companies to take advantage  of its Voluntary Disclosure Program.  The carrot is significant — a declination in exchange for cooperation, remediation and disgorgement....more

Proskauer - Whistleblower Defense

SEC Awards Two Whistleblowers More Than $98 Million

On August 23, 2024, the SEC announced payment of more than $98 million in total to two whistleblowers who provided the SEC with information and assistance that led to successful enforcement actions by the SEC and another...more

The Volkov Law Group

Tracking FCPA Individual Enforcement

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While FCPA enforcement against companies has been relatively quiet this year, despite a strong beginning to the year — the SAP case for $220 million; and the Gunvor case for $661 million — DOJ has been pushing a number of...more

The Volkov Law Group

DOJ Implements New Corporate Whistleblower Plan to Accelerate Corporate Criminal Enforcement (Part I of II)

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DOJ is feeling the heat.  Corporate criminal enforcement numbers are down. in fairness, DOJ has been pushing individual criminal enforcement as an effective deterrent to corporate misconduct.  Criminal prosecutions, when done...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Launches Corporate Whistleblower Awards Pilot Program and Announces a New Incentive for Self-Reports

On August 1, 2024, the Department of Justice’s Criminal Division launched the Corporate Whistleblower Awards Pilot Program (the Program), following up on its announcement in March 2024 of a plan to offer whistleblower awards....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

Proskauer - Whistleblower Defense

SEC Announces $37 Million Award to Whistleblower

On July 26, 2024, the SEC announced an award of more than $37 million to a whistleblower who first reported misconduct internally and subsequently provided information and assistance that led to a successful SEC enforcement...more

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

K&L Gates LLP

Federal Agencies Have Placed a Heightened Priority on Whistleblowers and Speedy Cooperation

K&L Gates LLP on

As new areas of the law emerge, driven in part by technology and the free flow of information, federal agencies are becoming more aggressive with a tried and true carrot-and-stick approach to law and regulatory enforcement. ...more

Husch Blackwell LLP

False Claims Act Insights - Eureka! Government Investigators Seek Out Research Misconduct

Husch Blackwell LLP on

Host Jonathan Porter welcomes Husch Blackwell attorney Karen Courtheoux to the show to discuss the False Claims Act in the context of government-funded research programs that are often carried out under the auspices of...more

Husch Blackwell LLP

The Justice Insiders Podcast - AI-Washing: Everything Old Is New Again

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Host Gregg N. Sofer welcomes Husch Blackwell attorney Rebecca Furdek back to the show to discuss recent government inquiries and enforcement actions concerning products and services related to artificial intelligence (AI)....more

Bracewell LLP

Digging for Trouble: The Double-Edged Sword of Decisions to Report Misconduct

Bracewell LLP on

On May 10, 2024, Romy Andrianarisoa, former Chief of Staff to the President of Madagascar, was convicted for soliciting bribes from Gemfields Group Ltd (Gemfields), a UK-based mining company specializing in rubies and...more

NAVEX

Celebrating World Whistleblower Day 2024

NAVEX on

“Whistleblower”. Rarely has a term provoked such lively and varied reactions in the political, economic and social spheres – and even in households! Traitors for some, heroes for others, these people, who were never...more

Jenner & Block

Client Alert: DOJ Continues Its Trend of Strengthening Incentives to Report Corporate Misconduct

Jenner & Block on

Just over a month after Deputy Attorney General Lisa Monaco announced the upcoming launch of the Department of Justice’s whistleblower rewards program, the DOJ Criminal Division unveiled its newest program to incentivize...more

Jenner & Block

DOJ Announces New Whistleblower Rewards Program and Enhanced Focus on AI-Related Risks

Jenner & Block on

The Department of Justice (DOJ) recently announced two new measures to enhance its corporate criminal enforcement efforts: a whistleblower rewards program and updated guidance under which federal prosecutors will assess risks...more

Holland & Knight LLP

Aumentan las sanciones por incumplimiento del SAGRILAFT y PTEE en empresas Colombianas

Holland & Knight LLP on

Dada la relevancia que actualmente está obteniendo la prevención de los riesgos y el cumplimiento normativo en el desarrollo de los negocios, la Delegatura de Asuntos Contables y Económicos de la Superintendencia de...more

Thomas Fox - Compliance Evangelist

The Trafigura FCPA Enforcement Action-Part 3-The Penalty

We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm trading firm G Trafigura Beheer B.V. (Trafigura), an international commodity trading company with its primary...more

The Volkov Law Group

Carrots and Sticks: DOJ’s Push to Incentivize Voluntary Disclosure of Corporate Misconduct (Part II of II)

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DOJ has been on a public relations campaign to push a simple message for corporations: if companies learn of misconduct, companies should disclose such misconduct to earn valuable benefits.  The quintessential question...more

Benesch

White Collar Quarterly Report | Q1 2024

Benesch on

We are thrilled to introduce the inaugural issue of our quarterly White Collar newsletter, a dedicated resource from Benesch’s White Collar, Government Investigations & Regulatory Compliance Practice Group. Each issue...more

Thomas Fox - Compliance Evangelist

The Trafigura FCPA Enforcement Action – Part 1 – Introduction

In March 2024, the Department of Justice (DOJ) announced the resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Swiss trading firm G Trafigura Beheer B.V. (Trafigura), an international...more

Cooley LLP

NSD’s Revised Enforcement Policy for Business Organizations Incentivizes Voluntary Self-Disclosures in M&A Context

Cooley LLP on

Companies engaged in mergers & acquisitions activities should take note of the revised voluntary self-disclosure policy (VSD Policy) of the National Security Division (NSD) of the US Department of Justice, released on March...more

Akin Gump Strauss Hauer & Feld LLP

DOJ National Security Division Updates Corporate Crime Enforcement Policy and Issues Whistleblower Policy

Executive Summary - - On March 7, 2024, the NSD of the DOJ issued an updated NSD Enforcement Policy to include a new section covering VSDs in connection with mergers and acquisitions. - These updates follow repeated...more

The Volkov Law Group

Gunvor Falls Under FCPA Axe and Agrees to Pay Criminal Penalty of $661 Million (Part I of III)

The Volkov Law Group on

You have to give the Justice Department credit — after two slow enforcement years, DOJ is starting off 2024 with a relative “bang;” first, DOJ reached a large settlement with SAP in January, and now, DOJ has reached a...more

Thomas Fox - Compliance Evangelist

The Gunvor FCPA Enforcement Action: Part 3-the Discounted Fine

We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm Gunvor S.A. The enforcement action came in with a $661 million penalty against the company, which has pleaded...more

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