Day 24 | CCO authority and independence
The Department of Justice has been relatively quiet this year in bringing corporate FCPA enforcement actions and settlements. Aside from the Ericsson breach of its Deferred Prosecution Agreement, the Corficocolombiana...more
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
A corporate compliance program can be thought of as a magnet that brings a company’s compliance efforts together. It is an operational program, not simply a code of expected ethical behavior. An effective compliance...more
At the start of 2023, we made a number of corporate criminal enforcement predictions. With 2023 launched, we are circling back to highlight initiatives that government contractors may wish to consider undertaking as...more
Self-Reporting Remains a Major Focus - Few executives expect to interact with the Department of Justice (DOJ) during their careers, but the current DOJ has given companies some homework, and the assignment applies to...more
Earlier in January 2023, the U.S. Department of Justice (DOJ) announced revisions to its Corporate Enforcement Policy (CEP) under the Foreign Corrupt Practices Act (FCPA) for the first time since 2017. In his speech...more
Last Tuesday, the Department of Justice (DOJ) announced the most recent modifications to its Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) in an effort to further encourage companies to...more
On January 17, 2023, Assistant Attorney General Kenneth A. Polite, Jr. (“AAG Polite”) announced several key revisions to the Department of Justice (“DOJ”) Criminal Division’s Corporate Enforcement Policy (the “CEP”) governing...more
On January 17, 2023, the Assistant Attorney General (AAG) for the Criminal Division of the U.S. Department of Justice (DOJ), Kenneth Polite, Jr., announced that DOJ had made “significant changes” to its Corporate Enforcement...more
On January 17, 2023, Assistant Attorney General (AAG) for the U.S. Department of Justice (DOJ) Criminal Division Kenneth Polite announced the “first significant changes” to the Criminal Division’s Corporate Enforcement Policy...more