News & Analysis as of

Enforcement Actions Self-Reporting White Collar Crimes

Eversheds Sutherland (US) LLP

DOJ releases new corporate crime enforcement guidance, telling companies what to expect—and how to avoid criminal penalties

On May 12, 2025, the US Department of Justice’s (DOJ) Criminal Division issued a memorandum titled Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime (the Memo) to all Criminal Division personnel. The...more

Alston & Bird

Carrots and Sticks Cross the Pond: The SFO’s New Corporate Self-Reporting and Cooperation Guidance

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The UK Serious Fraud Office (SFO) has issued new guidance to encourage companies to self-report suspected corporate criminal conduct and cooperate fully with investigations. Our transatlantic White Collar, Government &...more

Morrison & Foerster LLP

UK Serious Fraud Office Issues New Guidance on Corporate Cooperation and Enforcement

On 24 April 2025, the UK’s Serious Fraud Office (SFO) published new guidance for companies on cooperation and enforcement in relation to corporate criminal offending (Guidance). The Guidance outlines the SFO’s key...more

Ropes & Gray LLP

An Easier Route To Avoiding Corporate Prosecution? The UK’s SFO Announces A Shift In Strategy And New Corporate Cooperation...

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In what was a busy week for the Serious Fraud Office (SFO), much of the attention has focused on the launch of its new streamlined ‘External Guidance on Corporate Co-Operation and Enforcement in relation to Corporate Criminal...more

Hogan Lovells

SFO's new self-reporting guidance: A new deal or a departure from justice?

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On 24 April 2025, the Serious Fraud Office (SFO) issued new guidance signalling a notable shift in its approach to corporate criminal enforcement. For the first time, the SFO has stated that if a company self-reports...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Director of Enforcement Provides Insight on Recent Advisory

On March 27, 2025, the Futures Industry Association hosted a webinar with Brian Young, the director of the U.S. Commodity Futures Trading Commission (CFTC) Division of Enforcement. Although he noted that the opinions...more

Cadwalader, Wickersham & Taft LLP

Amid Chaos, Regulatory Change Continues Apace, March 2025 - New CFTC Enforcement Guidance

On February 25th, 2025, the Commodity Futures Trading Commission’s (“CFTC”) Division of Enforcement (“Division”) issued a long-awaited advisory (the “Advisory”) regarding its evaluation of how a company’s or individual’s...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Announces New Enforcement Advisory on Self-Reporting, Cooperation and Remediation

On February 25, 2025, the Division of Enforcement of the Commodity Futures Trading Commission (CFTC or the Commission) issued an advisory to Division staff on how to evaluate self-reporting, cooperation and remediation credit...more

Vinson & Elkins LLP

To Self-Report or Not to Self-Report: With New M&A Safe Harbor Policy, DOJ Tries to Answer the Question

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It is one of the hardest questions a company can face: after discovering criminal conduct inside your company, do you self-report to the government or not? If you can quickly and quietly fix the problem, then you may be able...more

Sheppard Mullin Richter & Hampton LLP

DOJ Touts Emerging Results from New Corporate Crime Self-Reporting Initiatives

The Department of Justice’s recent criminal self-reporting policy changes are beginning to show results, according to Assistant Attorney General Kenneth Polite Jr. Speaking at the New York City Bar Association’s White Collar...more

Sheppard Mullin Richter & Hampton LLP

“Sanctions Are The New FCPA”: DOJ Increases Focus on Sanctions and Export Control Enforcement

On March 2, 2023, Deputy Attorney General Lisa Monaco delivered remarks to the ABA’s National Institute on White Collar Crime. Unsurprisingly, her remarks focused heavily on inspiring a culture of compliance – including...more

Baker Donelson

Companies Take Heed: DOJ Announces Key Updates and Corporate Compliance Guidance

Baker Donelson on

On March 3, 2023, Assistant Attorney General Kenneth Polite delivered the keynote speech at the 38th Annual National Institute on White Collar Crime of the American Bar Association (ABA) in Miami, Florida. AAG Polite's speech...more

Alston & Bird

In Like a Lion: DOJ Enters March with a Flurry of Corporate Criminal Enforcement Activity

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Our White Collar, Government & Internal Investigations Team highlights key components of the Department of Justice’s recent corporate enforcement policy announcements....more

McDermott Will & Emery

DOJ Announces Major Changes to Corporate Compliance Program Evaluation Criteria

During speeches on March 2 and 3, 2023, at the American Bar Association (ABA) National Institute on White Collar Crime (the 2023 White Collar Conference), Deputy Attorney General (DAG) Lisa Monaco, Assistant Attorney General...more

Arnall Golden Gregory LLP

New DOJ Corporate Enforcement Policy Places Still More Pressure on Companies to Cooperate and Self-Report

Last month in a speech at Georgetown University Law Center, Assistant Attorney General Kenneth A. Polite, Jr., announced revisions to the Department of Justice’s Corporate Enforcement Policy, to apply to all corporate...more

Sheppard Mullin Richter & Hampton LLP

Corporate Voluntary Self-Disclosure (VSD) of Criminal Activity: More of the Same or a Real Sea Change?

On February 22, 2023, the U.S. Department of Justice (DOJ) announced a new nation-wide policy to incentivize companies to self-report criminal activity. Among the cited benefits of self-reporting are discounts on fines and...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Doubles Down on Efforts To Incentivize Early Self-Reporting and Cooperation

On January 17, 2023, the U.S. Department of Justice (DOJ) announced revisions to the Criminal Division’s Corporate Enforcement Policy. The revisions follow Deputy Attorney General (DAG) Lisa Monaco’s September 2022...more

Alston & Bird

More Carrot, Less Stick: DOJ Announces Corporate Enforcement Policy Revisions

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Our White Collar, Government & Internal Investigations Team breaks down how the Department of Justice is adjusting its enforcement policies to provide more incentives for corporate self-reporting and cooperation....more

Cadwalader, Wickersham & Taft LLP

DOJ Announces Formal Expansion of Corporate Enforcement Policy to Incentivize More Self-Reporting

On January 17, 2023, Assistant Attorney General Kenneth Polite announced revisions to the Department of Justice (DOJ) Criminal Division’s Corporate Enforcement Policy (CEP), expanding the availability of a potential full...more

Vinson & Elkins LLP

DOJ and SEC Stick Stericycle with a Two-Year Monitorship, Despite Acknowledgment of Extensive Remedial Measures

Vinson & Elkins LLP on

In yet another indication that the Biden administration is continuing to ramp up white collar enforcement, the U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced on April 20, 2022 that...more

Jones Day

DOJ Policy Increases Incentives for Self-Reporting of Potentially Willful Trade Violations

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The Situation: The U.S. Department of Justice ("DOJ") has issued guidance revising its 2016 voluntary disclosure policy to provide companies stronger incentives to voluntarily self-report apparent potentially willful trade...more

Foley & Lardner LLP

FCPA Notebook: Trends in 2019

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Foley & Lardner LLP’s International Government Enforcement Defense & Investigations team has created its latest FCPA infographic, which presents an overview of some high-level enforcement trends in an easy-to-view,...more

Butler Snow LLP

2019 Developments and Trends in the Foreign Corrupt Practices Act (FCPA) & Global Anti-Corruption Efforts, Part 2 of 3

Butler Snow LLP on

Previously, we introduced you to this topic and provided updates about the positive international trends in anti-corruption efforts, bribery, and the Organization for Economic Cooperation and Development (OECD). Today, we...more

Thomas Fox - Compliance Evangelist

TechnipFMC FCPA Enforcement Action-Lessons Learned

We continue our exploration of the TechnipFMC Foreign Corrupt Practices Act (FCPA) enforcement action by considering the actions taken by the company (or both separately before their merger) in response to their FCPA...more

Jones Day

CFTC Issues Advisory on Self-Reporting of Foreign Corrupt Practices for Non-Registrants

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The Advisory is part of the agency's broader commitment to provide "incentives for companies and individuals to engage in ethical corporate behavior." On March 6, 2019, the U.S. Commodity Futures Trading Commission...more

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