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Federal Sentencing Guidelines Compliance Criminal Prosecution

Husch Blackwell LLP

The Justice Insiders Podcast: Self-Disclosure, Cooperation, and the Hazards of Knowing Too Little

Husch Blackwell LLP on

Host Gregg N. Sofer welcomes Husch Blackwell partner Catherine Hanaway to the podcast to discuss the recent sentencing of Nishad Singh, a former key lieutenant of Sam Bankman-Fried, the cryptocurrency mogul responsible for...more

BakerHostetler

DOJ to Corporations - “Knock on Our Door Before We Knock on Yours”

BakerHostetler on

At last week’s ABA National White Collar Crime Institute, the leadership of the Department of Justice (the DOJ or the Department), including Attorney General Merrick Garland and Deputy Attorney General Lisa Monaco, made clear...more

Womble Bond Dickinson

Current Trends and Real-World Best Practices in Healthcare Fraud Compliance

Womble Bond Dickinson on

Recently, Womble Bond Dickinson held its First Annual Health Care Fraud Symposium, a webinar designed to discuss critical healthcare fraud topics. WBD Partner Joe Whitley moderated a discussion with WBD attorneys Luke Cass,...more

Jones Day

DOJ Announces New Voluntary Self-Disclosure Policy for All U.S. Attorneys' Offices

Jones Day on

On February 22, 2023, the U.S. Department of Justice ("DOJ" or "Department") announced the Voluntary Self-Disclosure Policy ("VSD Policy" or "Policy"), detailing the circumstances under which a company can receive credit for...more

Holland & Knight LLP

DOJ Makes Significant Revisions to Corporate Enforcement Policy

Holland & Knight LLP on

The U.S. Department of Justice (DOJ), through Assistant Attorney General Kenneth A. Polite Jr., announced on Jan. 17, 2023, "the first significant changes" to its Corporate Enforcement Policy (CEP) since 2017. The revisions...more

Society of Corporate Compliance and Ethics...

The Sentencing Guidelines at Thirty

The Organizational Sentencing Guidelines have turned thirty, and what began as an experiment is now an established framework for compliance programs in the US and around the globe. To commemorate the milestone, the United...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action - Part 4: The Double Whammy in Penalties

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

Foley & Lardner LLP

DOJ Antitrust Division Announces New Policy to Incentivize Corporate Compliance

Foley & Lardner LLP on

The Department of Justice Antitrust Division will now consider a target company’s antitrust compliance program when determining how to resolve criminal matters. This represents a fundamental shift in the Antitrust Division’s...more

A&O Shearman

Technology Company Resolves DOJ And SEC FCPA Allegations, With Hungary Subsidiary Entering Three-Year, Monitor-Free NPA

A&O Shearman on

On July 22, 2019, the United States Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced that they had resolved allegations of Foreign Corrupt Practice Act (“FCPA”) violations against...more

Dorsey & Whitney LLP

Newly Announced Antitrust Division Policy Rewards Effective Compliance Programs

Dorsey & Whitney LLP on

An effective antitrust compliance program is more valuable than ever, now that the Department of Justice has confirmed that such a program will influence government charging and sentencing decisions. On July 11, 2019,...more

Thomas Fox - Compliance Evangelist

Drum Solo Week 5: Ringo and The End – Microsoft FCPA Settlement – Part 4

Initially, it would not seem that much was new or different about the Microsoft FCPA enforcement action but through this exploration, I think some clear lessons have emerge. The first is around internal controls. Here there...more

Thomas Fox - Compliance Evangelist

Drum Solo Week 4: In-A-Gadda-Da-Vida – Microsoft FCPA Settlement – Part 3

Continuing our use of great drum solos to consider the Microsoft Foreign Corrupt Practices Act (FCPA) enforcement action, today we consider what Microsoft did to obtain their result. We have previously considered the...more

The Volkov Law Group

Microsoft Pays DOJ and SEC $25 Million to Resolve FCPA Violations (Part I of III)

The Volkov Law Group on

Microsoft finally resolved its FCPA enforcement action with a whimper.  Notwithstanding prior suggestions that Microsoft’s investigation uncovered global conduct, Microsoft’s liability focused primarily on Microsoft’s conduct...more

Wilson Sonsini Goodrich & Rosati

DOJ's Antitrust Division Announces New Policy Incentivizing Qualified Corporate Antitrust Compliance Programs

On July 11, 2019, Assistant Attorney General Makan Delrahim of the U.S. Department of Justice (DOJ) announced a new policy to incentivize corporate antitrust compliance. The DOJ will, for the first time, formally consider...more

Thomas Fox - Compliance Evangelist

Panasonic FCPA Enforcement Action: Part III – A 20% Discount

We continue our exploration of the Foreign Corrupt Practices Act (FCPA) enforcement action involving Panasonic Avionics Corporation (PAC) and its parent Panasonic Corporation (Panasonic)....more

Thomas Fox - Compliance Evangelist

This Week in FCPA-Episode 55, the Covfefe Edition

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. Brazilian meatpacker JBS agrees to the largest fine ever for fine for bribery and corruption, $3.2bn...more

Ruder Ware

Sally Yates’ was Already Famous for Changing the Focus of Compliance Investigations - The Yates Memorandum

Ruder Ware on

By now the whole world knows about Sally Yates. We are likely to see a lot more of her as a central figure in Congressional investigations. For some of us who deal with compliance investigations, Sally Yates was famous long...more

Sheppard Mullin Richter & Hampton LLP

DOJ Issues New Guidance on the Evaluation of Corporate Compliance Programs in Federal Fraud Investigations

On February 8th, the U.S. Department of Justice (DOJ) quietly issued new guidance on how the agency evaluates corporate compliance programs during fraud investigations. The guidance, published on the agency’s website as the...more

Jones Day

Department of Justice Fraud Section Provides Guidance on Evaluating Corporate Compliance Programs

Jones Day on

On February 8, 2017, the United States Department of Justice ("DOJ") Fraud Section published a blueprint for assessing corporate compliance efforts, titled "Evaluation of Corporate Compliance Programs" ("Guidance"). It...more

Ruder Ware

Department of Justice Issues Principles of an Effective Compliance Program

Ruder Ware on

The Department of Justice issued a directive entitled “Evaluation of Corporate Compliance Programs.” The document provides insight into the analysis used by the DOJ to assess the effectiveness of a corporate compliance...more

NAVEX

New Guidance from the DOJ on Your Compliance Program

NAVEX on

The U.S. Department of Justice (DOJ), Criminal Division, Fraud Section, recently released new guidance associated with its Guide to the U.S. Foreign Corrupt Practices Act. The guidance, entitled Evaluation of Corporate...more

Pillsbury Winthrop Shaw Pittman LLP

New FCPA Self-Reporting Pilot Program Formalizes Rewards but Relies on Discretionary Implementation

On April 5, 2016, the Department of Justice unveiled a one-year pilot program designed to encourage companies to self-report violations of the Foreign Corrupt Practices Act (the FCPA). Built upon the Department’s September 9,...more

Parker Poe Adams & Bernstein LLP

Is Confession Good for the Corporate Soul?: DOJ announces new mitigation credit for self-disclosure of FCPA violations

On April 5, 2016, the Department of Justice’s (“DOJ”) Fraud Section Chief, Andrew Weissmann, issued a memo (the “Weissmann Memorandum”) announcing a one-year Pilot Program that offers a carrot and stick approach to...more

WilmerHale

DOJ Launches FCPA Pilot Program to Encourage Corporate Voluntary Disclosure and Cooperation

WilmerHale on

On April 5, 2016, the Fraud Section of the Department of Justice's (DOJ) Criminal Division issued an enforcement plan and guidance (the Guidance) laying out three steps it is taking to intensify Foreign Corrupt Practices Act...more

Foley & Lardner LLP

DOJ Fraud Section Offers Super Credit in FCPA Pilot Program

Foley & Lardner LLP on

This week, the Fraud Section of the Department of Justice (DOJ) announced a pilot program that extends additional “mitigation credit” to qualifying companies that “fully cooperate” in matters involving the Foreign Corrupt...more

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