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Deferred Prosecution Agreements Cooperation

WilmerHale

UK Serious Fraud Office Issues New Self-Reporting and Corporate Cooperation Guidance

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On 24 April 2025, the UK Serious Fraud Office (SFO) issued new guidance to encourage companies to self-report suspected corporate wrongdoing.  The guidance states that self-reporting, combined with full cooperation with the...more

Seyfarth Shaw LLP

Updated SFO Guidance: Familiar Framework, Sharper Focus—Timing Is Everything

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The Serious Fraud Office (SFO) is raising the stakes. With the publication of new Co-operation and Enforcement Guidance on 24 April 2025, the agency is ramping up enforcement and clarifying expectations for corporate...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Serious Fraud Office Releases New Guidance on Self-Reporting, Cooperation and Deferred Prosecution Agreements

On 24 April 2025, the Serious Fraud Office (SFO) released new guidance on corporate self-reporting, cooperation and deferred prosecution agreements (DPAs)....more

Latham & Watkins LLP

Key Takeaways From the SFO’s New Corporate Guidance

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The updated guidance puts a heavy emphasis on self-reporting and clarifies how corporates under investigation can earn cooperation credit from UK prosecutors....more

Latham & Watkins LLP

SFO Announces Ambitious Five-Year Plan

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The Serious Fraud Office’s strategy for 2024 to 2029 indicates aspiration to be a more effective agency and to incentivise personnel. On 18 April 2024, the UK’s Serious Fraud Office (SFO) published an ambitious, albeit...more

BakerHostetler

DOJ to Corporations - “Knock on Our Door Before We Knock on Yours”

BakerHostetler on

At last week’s ABA National White Collar Crime Institute, the leadership of the Department of Justice (the DOJ or the Department), including Attorney General Merrick Garland and Deputy Attorney General Lisa Monaco, made clear...more

Thomas Fox - Compliance Evangelist

The SAP FCPA Enforcement Action-Part 4: The Fines: Self-Disclose, Self-Disclose, Self-Disclose

We continue our exploration of the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. Today we go full geek in a look at the fine and penalty and most importantly what the fine and penalty communicate about what the...more

HaystackID

Cooperation Standards in Government Investigations: Practical Tips

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Editor’s Note: From time to time, ComplexDiscovery highlights publicly available or privately purchasable announcements, content updates, and research from cyber, data, and legal discovery providers, research organizations,...more

Latham & Watkins LLP

DOJ Announces Policy Changes to “Invigorate” Efforts to Combat Corporate Crime - Japanese Version

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今回の米国司法省の政策変更において、司法省は個人の責任に一層の重点を置き、また企業の過去の違法行為に対しては包括的な評価を行い、さらに企業との司法解決に対してはより厳格な対応をすることとなる - 2021年10月28日、米国司法省 (United States Department of Justice、以下「DOJ」)...more

Eversheds Sutherland (US) LLP

US Department of Justice adopts “bold” approach to prosecuting corporate crime and will engage in “rigorous enforcement”

On October 28, 2021, Deputy Attorney General (Deputy AG) Lisa O. Monaco gave remarks explicitly warning companies that the US Department of Justice (DOJ) intends to increase its efforts and devote additional resources to...more

Latham & Watkins LLP

DOJ Announces Policy Changes to “Invigorate” Efforts to Combat Corporate Crime

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The changes include more focus on individual accountability, more holistic evaluation of prior corporate misconduct, and stricter corporate resolutions. On October 28, 2021, US Deputy Attorney General Lisa Monaco gave the...more

BCLP

The SFO, the Goose and the Golden Eggs: What the SFO’s New Guidance on DPAs Tells Us About the Prosecutor’s Approach to...

BCLP on

On 23 October 2020, the SFO published a chapter from its Operational Handbook, including an expanded section on corporate co-operation, so as to give “comprehensive guidance” on the organisation’s approach to the use of...more

WilmerHale

Airbus to Pay Record $4 Billion to Settle Global Bribery Scheme

WilmerHale on

On January 31, 2020, the Department of Justice (“DOJ”) agreed to resolve allegations that Airbus SE (“Airbus”), a France-based aerospace company, used third-party business partners to bribe government officials and airline...more

WilmerHale

$1 Billion Ericsson Resolution, Three Jury Verdicts Cap Off Busy Fourth Quarter for US FCPA Enforcement

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On December 6, 2019, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) agreed to resolve allegations that multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson or...more

The Volkov Law Group

Avanir Pharmaceuticals Pays More than $108 Million to Settle Kickback Violations

The Volkov Law Group on

Just to repeat myself – pharmaceutical and medical device firms face extraordinary risks of enforcement under the False Claims Act.  While everyone likes to write and focus on FCPA or anti-corruption risks for global drug and...more

BCLP

SFO Corporate Co-operation Guidance – A flawed approach and a wasted opportunity

BCLP on

The much heralded Corporate Co-operation Guidance published by the Serious Fraud Office recently offers little comfort to corporates struggling with the dilemma of whether to self-report wrongdoing. Instead it offers a...more

Foley & Lardner LLP

DOJ Antitrust Division Announces New Policy to Incentivize Corporate Compliance

Foley & Lardner LLP on

The Department of Justice Antitrust Division will now consider a target company’s antitrust compliance program when determining how to resolve criminal matters. This represents a fundamental shift in the Antitrust Division’s...more

White & Case LLP

Co-operation or Capitulation? – What the SFO Corporate Co-operation Guidance really means

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Is there a point at which co-operation becomes capitulation? Is there a danger inherent in co-operating without the guarantee of a favourable outcome for doing so?...more

Kramer Levin Naftalis & Frankel LLP

The First PNF/AFA Common Guidelines

When Law No. 2016-1691 (Sapin II Law) created the convention judicaire d’intérêt public (CJIP), modeled after the American deferred prosecution agreement (DPA), it was feared that the existence of potentially dueling French...more

WilmerHale

UK Serious Fraud Office Publishes Corporate Co-Operation Guidance

WilmerHale on

On 6 August 2019, the UK Serious Fraud Office (‘SFO’) published Corporate Co-operation Guidance (‘Guidance’). This Guidance is designed to assist companies considering whether to self-report corporate wrongdoing to the SFO...more

Morrison & Foerster LLP

The UK’s Serious Fraud Office Issues Guidance for Corporate Cooperation

On 6 August 2019, the UK’s Serious Fraud Office (SFO) released Guidance on what it expects from organisations seeking cooperation credit in the agency’s investigations. The long-awaited Guidance is a codified and clarified...more

Bracewell LLP

DOJ Changes Criminal Policy to Recognize Antitrust Compliance Programs

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In a major policy shift, the Antitrust Division of the Department of Justice recently announced that it will now credit companies for effective corporate antitrust compliance programs in making charging decisions and penalty...more

Latham & Watkins LLP

New DOJ Guidance Increases Benefits for Robust Antitrust Compliance Programs - What Companies Need to Know

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The Antitrust Division’s new policy gives credit for pre-existing compliance programs, but only those that meet certain high standards. On July 11, 2019, Assistant Attorney General Makan Delrahim announced that the US...more

Wilson Sonsini Goodrich & Rosati

DOJ's Antitrust Division Announces New Policy Incentivizing Qualified Corporate Antitrust Compliance Programs

On July 11, 2019, Assistant Attorney General Makan Delrahim of the U.S. Department of Justice (DOJ) announced a new policy to incentivize corporate antitrust compliance. The DOJ will, for the first time, formally consider...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - June 2019

ANTICORRUPTION DEVELOPMENTS - Deputy Assistant Attorney General Matt Miner Delivers Remarks at the American Bar Association, Criminal Justice Section Third Global White Collar Crime Institute Conference - On June 27,...more

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