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Department of Justice (DOJ) Clawbacks

Foley Hoag LLP - White Collar Law &...

Anticorruption and FCPA Enforcement: Takeaways and Lessons Heading into 2025

This is the second in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more

Society of Corporate Compliance and Ethics...

Understanding the Latest DOJ Changes to Corporate Prosecutions

On November 22, 2024, then Principal Deputy Assistant Attorney General Nicole Argentieri recapped the changes made during the Biden Administration in enforcement policies and announced a few new ones. To better understand...more

Morrison & Foerster LLP

White Collar Enforcement Priorities and Challenges: Discussions from “Views at the Top”

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On December 11, 2024, the Women’s White Collar Defense Association (WWCDA) hosted “Views from the Top,” featuring the following government officials from the DOJ, SEC, CFTC, and FTC discussing current and future enforcement...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for November 2024

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Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Foley & Lardner LLP

Executing Audit Committee Oversight in Turbulent Times: Risk Management and Financial Reporting

Foley & Lardner LLP on

Foley & Lardner LLP recently sponsored NACD Northern California’s “Executing Audit Committee Oversight in Turbulent Times: Risk Management and Financial Reporting” dinner. Foley partners Sandy Winer, Lauren Valiente, and Nick...more

Bradley Arant Boult Cummings LLP

TD Bank’s Historic $3.1B Money Laundering Settlement a Warning to All Financial Institutions

On October 10, 2024, Attorney General Merrick Garland announced that TD Bank agreed to pay over $1.8 billion in penalties to resolve the U.S. Department of Justice’s (DOJ) investigation into money laundering and Bank Secrecy...more

Bracewell LLP

Keeping an Eye on AI: DOJ Updates its Playbook for Corporate Compliance

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On September 23, 2024, Principal Deputy Assistant Attorney General Nicole Argentieri announced that the US Department of Justice (DOJ) had issued updated guidance to federal prosecutors in its “Evaluation of Corporate...more

Eversheds Sutherland (US) LLP

DOJ emphasizes importance of AI risk mitigation, whistleblower protections, and clawback compensation policies

Last Monday, the Department of Justice (the DOJ or the Department) announced significant updates to the DOJ Criminal Division’s Evaluation of Corporate Compliance Programs (ECCP). These updates discuss, for the first time,...more

Thomas Fox - Compliance Evangelist

The Argentieri Speech: Mid-Point Reflections on the DOJ’s Compensation Clawback Pilot Program

Principal Deputy Assistant Attorney General Nicole M. Argentieri spoke at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute. She reiterated the long-stated policy that compliance...more

Thomas Fox - Compliance Evangelist

The Boston Consulting Group Declination: A Money Shot for Clawbacks

In a recent development that has garnered significant attention in the compliance community, the U.S. Department of Justice (DOJ) declined prosecution of Boston Consulting Group, Inc. (BCG) for violations of the Foreign...more

Epiq

Compliance Programs Under Scrutiny

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In today’s regulatory environment, corporations have a heightened obligation to investigate potential wrongdoing by their employees and to monitor, and possibly disclose, incidents of illegal conduct....more

Health Care Compliance Association (HCCA)

Cleveland Clinic Pays $7.6M Related to PI Whose Charges Were Dropped; ‘He Was Treated Horribly’

Attorney Peter Zeidenberg was surprised to learn that NIH had successfully clawed back $3.6 million—plus a nearly 100% penalty—from Cleveland Clinic. The Department of Justice (DOJ) claimed the award funds were ill-gotten...more

Jackson Lewis P.C.

“Knock on our door before we knock on yours:” Recent DOJ Trends

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On March 7, 2024, Deputy Attorney General Lisa Monaco (“DAG Monaco”) gave the keynote address at the American Bar Association’s 39th National Institute on White Collar Crime. She addressed the success she views in the...more

American Conference Institute (ACI)

[Event] The Brazil Summit on Anti-Corruption, Integrity & ESG - May 22nd - 23rd, São Paulo, Brazil

Hosted by American Conference Institute, the 14th Annual Summit on Anti-Corruption, Integrity & ESG returns to Brazil for another groundbreaking year to discuss the current high-stakes dilemmas impacting your organization....more

American Conference Institute (ACI)

[Event] FCPA & Anti-Corruption for the Life Sciences Industry - May 9th - 10th, New York, NY

Hosted by the American Conference Institute, the 19th Annual FCPA & Anti-Corruption Conference for the Life Sciences Industry returns for another exciting year with carefully researched programming based on critical findings...more

Axinn, Veltrop & Harkrider LLP

Axinn at the 2024 ABA White Collar Crime Conference

The 2024 ABA White Collar Crime Conference in San Francisco was filled with insightful discussion on hot topics in recent U.S. criminal enforcement as Department of Justice enforcers offered views into current and future...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements – Lesson No. 8, Enhancing Your Compliance Program

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 6, Clawbacks and Holdbacks

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

NAVEX

How to Meet the Letter, Spirit and Intent of the DOJ’s Evolving Compliance Program Expectations

NAVEX on

With any new administration, the U.S. Department of Justice (DOJ) often shifts focus from one set of enforcement priorities to another. However, one area has remained a focus from administration to administration: guidance...more

Mintz

EnforceMintz — DOJ and OIG Guidance Emphasizes the Importance of a Robust and Dynamic Compliance Program

Mintz on

2023 was a busy year across several federal agencies in terms of issuing compliance guidance for corporations, including health care companies. For example, the Department of Justice (DOJ) issued significant compliance...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for January 2024

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2023 Developments and Predictions for 2024

WilmerHale on

Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more

Sheppard Mullin Richter & Hampton LLP

2024 Top-of-Mind Issues for Life Sciences Companies

As we reflect on 2023 and make predictions for 2024, it is remarkable the number of significant events occurring this past year that will be impactful for the activities of the life sciences industry going forward. Although...more

Seward & Kissel LLP

Bad Intentions, Demanding a Refund, Leaving the Station, The Lord(stown) Giveth, and Poor Choice

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Celsius files intent to claw back certain pre-bankruptcy withdrawals| CoinTelegraph - On January 9, Celsius bankruptcy administrators notified creditors that account holders who took out more than $100,000 in the 90 days...more

ArentFox Schiff

How to Avoid an Independent Compliance Monitor: Lessons From the SAP Settlement

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This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more

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