Day 24 | CCO authority and independence
Summary - The Department of Justice (DOJ) has created the International Corporate Anti-Bribery initiative (ICAB), which aims to strengthen the United States’ global efforts in combating corruption through enhanced...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
On January 17, 2023, Assistant Attorney General Kenneth A. Polite delivered remarks announcing revisions to the Department of Justice (“DOJ”) Criminal Division’s Corporate Enforcement Policy (“CEP”) at Georgetown Law Center. ...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
In Short - The Situation: On January 17, 2023, the U.S. Department of Justice ("DOJ" or "Department") announced significant revisions to the Criminal Division's Corporate Enforcement Policy....more
The US Department of Justice (DOJ) continues to try to dispel lingering skepticism over the benefits of corporate disclosure and cooperation. In remarks delivered on January 17, Assistant Attorney General (AAG) Kenneth A....more
On January 17, 2023, the Department of Justice (DOJ) rolled out a significant change to its existing Corporate Enforcement Policy (CEP) that will grant as much as a 75% reduction in fines for companies that voluntarily...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
In a recently published memorandum, Deputy Attorney General (DAG) Lisa Monaco announced important updates to the U.S. Department of Justice’s (DOJ’s) approach to investigating and prosecuting corporate crimes. In the...more
On 23 October 2020, the UK Serious Fraud Office (SFO) updated its Operational Handbook, publishing a new chapter on deferred prosecution agreements (DPAs) (the Chapter). This note summarizes key points from the Chapter and...more
There was a perception in 2017 when then President-elect Trump took office that white collar enforcement actions under the US Department of Justice (DOJ) might drop dramatically. Many expected the Republican administration to...more
Editors’ Note: This is the third in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed healthcare fraud in 2020. Up next: a look at...more
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
In a record year, there are bound to be numerous interesting enforcement actions and principles. I picked out a few to highlight....more
Welcome to the 2020’s. The past decade helped shape both Foreign Corrupt Practices Act (FCPA) enforcement and corporate compliance programs. 2019 FCPA enforcements bore out many of the developments from the preceding years of...more
Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more
The Department of Justice recently announced updates to its Foreign Corrupt Practices Act Corporate Enforcement Policy. While the changes were relatively minor, the modifications underscored important principles surrounding...more
The Department of Justice tweaked its FCPA Corporate Enforcement Policy to further incentivize corporations to make voluntary disclosures. These small changes essentially acknowledge that companies in a very early stage of an...more
Here we go – another year, another set of predictions. Who knows whether they will come true? Actually, I went back and read my annual prediction posting for 2018 and 2017, respectively. Some things I called correctly, and...more
In a development with potentially far-reaching consequences for white collar enforcement, the U.S. Department of Justice (DOJ) Criminal Division has expanded the opportunity for companies to earn credit for voluntary...more