News & Analysis as of

Corruption Federal Pilot Programs

Ogletree, Deakins, Nash, Smoak & Stewart,...

Whistleblower Update: SEC, DOJ Still Focusing on Employment Agreements and Written Policies, Off-Channel Communications

The U.S. Securities and Exchange Commission (SEC) brought more actions targeting regulated entities for recordkeeping violations related to employees using noncompany communications platforms, and both the SEC and the U.S....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

Baker Donelson

Update: DOJ Launches Corporate Whistleblower Awards Program

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In March, the Department of Justice (DOJ) announced that a pilot program to incentivize individualized reporting was in development, which we reviewed here. True to its word, the DOJ's "Corporate Whistleblower Awards Pilot...more

Mayer Brown

US Department of Justice Whistleblower Award Program Goes Live

Mayer Brown on

On August 1, 2024, the US Department of Justice (“DOJ” or “Department”) released highly anticipated details of its new Corporate Whistleblower Awards Pilot Program (“Pilot Program”), with Principal Deputy Assistant Attorney...more

Holland & Knight LLP

Justice Department Announces New Corporate Whistleblower Pilot Program

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After announcing at the ABA White Collar Crime Conference last winter that it would engage in a months-long "policy sprint," the U.S. Department of Justice (DOJ or Department) released its Corporate Whistleblower Awards Pilot...more

Bradley Arant Boult Cummings LLP

Criminal Division’s new voluntary self-disclosure program still uncertain and risky

On April 15, 2024, the Department of Justice released its “Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals.” Similar in many ways to programs introduced earlier this year by the U.S. Attorney’s...more

Epstein Becker & Green

The Department of Justice’s Criminal Division Launches a Pilot Program on Voluntary Self-Disclosures for Individuals

Epstein Becker & Green on

Since October 2021, the Department of Justice (DOJ) has been implementing a variety of changes to its corporate criminal enforcement policies. These efforts all reflect DOJ’s focus on individual accountability, punishing...more

White & Case LLP

DOJ Announces Pilot Program to Pay Monetary Rewards to Whistleblowers

White & Case LLP on

During the American Bar Association's 39th National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco announced the launch of the U.S. Department of Justice's (DOJ or the Department) pilot program to...more

Mayer Brown

US Department of Justice Announces Sprint Towards New Whistleblower Reward Program

Mayer Brown on

On March 7, 2024, the Deputy Attorney General of the US Department of Justice (“DOJ” or “Department”) announced a pilot program to encourage whistleblowers to report evidence of high-priority white collar crimes with the...more

Littler

Proper Planning and Swift Action Can Help Employers Avoid Foreign Corrupt Practices Act Prosecution

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While the Department of Justice (DOJ) has initiated at least two new Foreign Corrupt Practices Act (FCPA) enforcement actions against U.S. companies, it has also announced several decisions not to prosecute—most recently...more

Thomas Fox - Compliance Evangelist

On the Importance of Effective Compliance Programs (and subregulatory guidance)

Compliance Week 2019 is in full swing. The conference opened with a very interesting talk by Principal Deputy Associate Attorney General Claire McCusker Murray. She provided some excellent insights for the compliance...more

Thomas Fox - Compliance Evangelist

Evolution of Best Practices – Part I

Perhaps the most consistent process in the compliance field is its evolution. Compliance programs began in response to the US Sentencing Guidelines for Corporations back in 1992....more

BakerHostetler

Foreign Corrupt Practices Act 2017 Year-End Update

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2017 marked the fortieth anniversary of the Foreign Corrupt Practices Act (FCPA), and showed continued robust enforcement against both individuals and companies by the U.S. Department of Justice (DOJ) and the U.S. Securities...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

The Volkov Law Group

Pushing Ethics and Compliance Programs in the New FCPA Corporate Enforcement Policy

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The Justice Department’s aggressive enforcement program, particularly in the FCPA arena, has been the primary impetus to the growth and empowerment of the corporate compliance function. The Justice Department and SEC’s FCPA...more

Thomas Fox - Compliance Evangelist

Compliance Under the New FCPA Enforcement Policy – Final Thoughts

Over the past few posts I have been exploring the Department of Justice’s (DOJ) new policy regarding Foreign Corrupt Practices Act (FCPA) enforcement. Deputy Attorney General Rod Rosenstein, in a speech, called it the FCPA...more

K&L Gates LLP

Takeaways from the 34th International Conference on the Foreign Corrupt Practices Act

K&L Gates LLP on

At the 34th International Conference on the Foreign Corrupt Practices Act held last week in Washington, D.C., industry executives, members of the defense bar, and regulators examined developments in the enforcement of the...more

Thomas Fox - Compliance Evangelist

Compliance Under the New FCPA Enforcement Policy – Clarification and Consolidation

Last week, the Department of Justice (DOJ) premiered a new policy regarding Foreign Corrupt Practices Act (FCPA) enforcement. Deputy Attorney General Rod Rosenstein, in a speech, called it the FCPA Corporate Enforcement...more

A&O Shearman

DOJ Issues Two Declinations in First Corporate FCPA Enforcement Actions of the Trump Administration

A&O Shearman on

Speed read - In June 2017, the U.S. Department of Justice (DOJ) issued two “Declinations with Disgorgement” under the DOJ’s Pilot Program. The declinations were received by U.S. subsidiaries of the Linde Group (Linde) and...more

The Volkov Law Group

Justice Department Resolves Two Cases Under FCPA Pilot Program

The Volkov Law Group on

The Justice Department recently resolved two separate FCPA investigations under its Pilot Program. To be sure, DOJ’s resolution of these two matters reinforces the real and tangible benefits of its Pilot Program....more

Thomas Fox - Compliance Evangelist

Has the FCPA changed the US business culture?

In the early 70’s the Lockheed corruption scandals came into light. Millions of dollars had been paid by the US aircraft corporation to public officials to guarantee contracts for military aircraft in Germany, Italy, Japan,...more

The Volkov Law Group

Transparency in FCPA Enforcement

The Volkov Law Group on

We all value transparency as a general concept, especially when it comes to the government. In a real macro perspective, we fund the government and we demand that our government operate efficiently, effectively and ethically....more

Foley & Lardner LLP

The Foreign Corrupt Practices Act and the New Trump Administration: Your Top Ten Questions Answered

Foley & Lardner LLP on

Since mid-2000s investigation of Siemens, and the resulting $800 million penalty for violations of the Foreign Corrupt Practices Act (FCPA), the FCPA has been an enforcement priority of the U.S. Government. Although a dip in...more

The Volkov Law Group

What is the Real Risk of an FCPA Enforcement Action?

The Volkov Law Group on

When speaking to clients or potential clients, the question of risk of enforcement is the moose on the table. Sometimes, the question gets asked and other times, the subject is never discussed. To be fair, it is not an easy...more

Thomas Fox - Compliance Evangelist

The FCPA at 40 – FCPA Enforcement and the International Fight Against Bribery

In two speeches last week Department of Justice (DOJ) Acting Principal Assistant Attorney General Trevor McFadden addressed multiple topics and issues around the Foreign Corrupt Practices Act (FCPA). The first set of remarks...more

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