Episode 405 -- DOJ Balt Declination: Individual Accountability in Action
Episode 383 -- FCPA Update: Declination and Indictment
Daily Compliance News: May 19, 2025, The Definition of Corruption Edition
FCPA Compliance and Enforcement in Brazil: DOJ and SEC Alumni Provide Critical Updates and The Newest Compliance Best Practices
Day 24 | CCO authority and independence
Less than three months after its launch, the Southern District of New York (SDNY) has produced its first publicly confirmed outcome under its new Corporate Enforcement and Voluntary Self-Disclosure Program for Financial...more
Your company uncovers a massive criminal scheme. Are you gonna go down with the ship or are you gonna grab onto the lifeboat that the Justice Department has sent your way?...more
On March 10, 2026, the Department of Justice announced what it described as the “first-ever Department-wide corporate enforcement policy for criminal matters,” covering all corporate criminal matters except for antitrust...more
On March 10, 2026, the Department of Justice (DOJ) released the first-ever Corporate Enforcement (CEP) Policy designed to promote uniformity and predictability across the nation’s 94 United States Attorney’s Offices. The CEP...more
The Department of Justice’s recent declination in the Balt Medical matter provides another important data point in understanding how DOJ is applying its updated Corporate Enforcement and Voluntary Self-Disclosure Policy in...more
Highlights from March 2026 include FCPA charges for two startup founders but a declination for the company, the conclusion of the DOJ’s investigation into Dr. Reddy’s Laboratories, a bill to double the FCPA’s statute of...more
Key Takeaways - What Happened: The U.S. Department of Justice (DOJ) issued its first department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy for corporate criminal matters. Within days, DOJ applied it to...more
Background - The U.S. Department of Justice (“DOJ”) released its first-ever, department-wide,1 Corporate Enforcement and Voluntary Self-Disclosure Policy (“CEP”) for criminal matters....more
In this episode, we examine the Department of Justice’s declination in the Balt Medical case—a textbook example of how DOJ is applying its Corporate Enforcement Policy in practice. Despite a multi-year foreign bribery scheme...more
In-house counsels across Asia-Pacific are increasingly operating at the intersection of two powerful forces. Under the current Trump administration, U.S. enforcement priorities are shifting, while the regional regulatory...more
Last month, the United States Department of Justice (DOJ) released a Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) which, for the first time in the DOJ’s history, applies across the entire DOJ with the...more
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
For years, the Department of Justice has tried to sharpen a simple message: companies that voluntarily disclose misconduct, cooperate fully, remediate effectively—and identify responsible individuals—can earn significant...more
The U.S. Department of Justice (“DOJ”) has for the first time ever issued a uniform Corporate Enforcement and Voluntary Self-Disclosure Policy (“CEP”), taking another step toward standardizing corporate crime enforcement by...more
Recent Developments - Department of Justice Releases First-Ever Corporate Enforcement Policy for All Criminal Cases - On March 10, 2026, the Department of Justice (“DOJ”) announced that it was releasing its first-ever...more
While regulatory turbulence is always a challenge, 2026 may represent an especially notable year given political changes in key international markets. Although compliance programs will need to prepare and adapt to changing...more
On March 19, 2026, the Department of Justice (“DOJ”) announced that it was declining to prosecute Balt SAS, a France-based medical device company, and its subsidiary Balt USA LLC (together, “Balt”), in connection with an...more
The United States Department of Justice (DOJ) and France’s Parquet National Financier (PNF) recently announced coordinated settlements with Balt SAS, a French medical device manufacturer, and its American affiliate, Balt USA...more
On March 10, 2026, the Department of Justice (DOJ) issued a new Corporate Enforcement and Voluntary Self-Disclosure Policy (“CEP”), which now governs all corporate criminal matters handled by DOJ except for antitrust...more
The most important aspect of DOJ’s revised Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy may be its unmistakable message to compliance professionals: a compliance program will be judged not by...more
The final quarter of 2025 produced a modest resurgence in Foreign Corrupt Practices Act (FCPA) activity following the administration’s June 2025 FCPA guidelines....more
Last week, the U.S. Department of Justice (DOJ) introduced a new Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (“Department-wide CEP” or “Policy”). On Thursday, DOJ announced what it is calling...more
On March 10, 2026, the US Department of Justice (DOJ) announced a new Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) aimed at creating a unified, department-wide framework designed to incentivize companies...more
On March 10, 2026, the US Department of Justice (DOJ) released its first-ever Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), which is the latest in a series of directives intended to offer a clearer path to...more
One of the most significant recent corporate enforcement trends is the rise in voluntary self-disclosure (VSD) policies offered by a variety of regulatory agencies, including the Department of Justice, the Office of Foreign...more