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Federal Sentencing Guidelines Cooperation

BakerHostetler

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

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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

Thomas Fox - Compliance Evangelist

The SAP FCPA Enforcement Action-Part 4: The Fines: Self-Disclose, Self-Disclose, Self-Disclose

We continue our exploration of the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. Today we go full geek in a look at the fine and penalty and most importantly what the fine and penalty communicate about what the...more

Beveridge & Diamond PC

DOJ Implements Nationwide “Voluntary Self-Disclosure” Program: All U.S. Attorneys’ Offices Instructed to Follow Updated Corporate...

The U.S. Department of Justice (DOJ) formally implemented a nationwide Voluntary Self-Disclosure policy (VSD policy) on February 22, 2023—effective immediately—that has been in the works for several years. The VSD policy...more

Jenner & Block

Client Alert: DOJ Expands the Reach of Its Policies on Self-Disclosure of Corporate Misconduct

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On February 22, 2023, the Department of Justice announced a new Voluntary Self-Disclosure Policy (the Disclosure Policy) that now governs corporate prosecutions by US Attorney’s Offices (USAOs) nationwide. Building on a 2022...more

Holland & Knight LLP

DOJ Makes Significant Revisions to Corporate Enforcement Policy

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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

Foley & Lardner LLP

DOJ Antitrust Division Announces New Policy to Incentivize Corporate Compliance

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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

Latham & Watkins LLP

Gesetzentwurf zur Bekämpfung der Unternehmenskriminalität bringt neue Regeln für interne Untersuchungen – Datenschutz gewinnt...

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Das Justizministerium arbeitet mit Hochdruck an einem Entwurf für ein Unternehmensstrafrecht. Der Entwurf verfolgt das Ziel, die Sanktionierung von Unternehmen und sonstigen Verbänden auf eine eigene gesetzliche Grundlage zu...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

Holland & Knight LLP

Cooperation Credit in False Claims Act Cases

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Companies facing liability under the False Claims Act (FCA) often desire early resolution with the Department of Justice (DOJ) through settlement. Hand in hand with the decision to settle comes the decision of whether or not...more

Bracewell LLP

DOJ Issues New Policy Encouraging Self-Reporting FCPA Violations

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On November 29, 2017 the Deputy Attorney General of the U.S. Department of Justice (DOJ), Rod J. Rosenstein, announced a new FCPA enforcement policy that seeks to incentivize voluntary self-reporting by providing companies...more

Ruder Ware

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

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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

WilmerHale

Global Anti-Bribery Year-in-Review: 2016 Developments and Predictions for 2017

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The past year was consequential for FCPA enforcement in numerous respects, including blockbuster penalties, new policy initiatives, and the SEC’s first DPA with an individual for FCPA violations. In April 2016, the DOJ’s...more

Carlton Fields

DOJ’s FCPA Pilot Program Keeps Heat on Individuals

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In April, the Department of Justice (DOJ) announced a one-year pilot program offering certain violators of the Foreign Corrupt Practices Act (FCPA) the possibility of reduced sanctions on top of any credit provided for by the...more

Dorsey & Whitney LLP

Dorsey Anti-Corruption Digest - April 2016

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Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more

Dechert LLP

New US Department of Justice Foreign Corrupt Practices Act Enforcement Plan Creates "Pilot Program" to Encourage Voluntary...

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The U.S. Department of Justice (“DOJ”) released a memorandum (the “FCPA Enforcement Memorandum”) on April 5, 2016 detailing a new enforcement plan for Foreign Corrupt Practices Act (“FCPA”) investigations. The DOJ announced...more

Skadden, Arps, Slate, Meagher & Flom LLP

"DOJ Adds Resources for FCPA Cases, Offers Incentives for Voluntary Disclosures"

On April 5, 2016, the Department of Justice’s (DOJ) Fraud Section made two related announcements in its Foreign Corrupt Practices Act (FCPA) Enforcement Plan and Guidance. First, the Fraud Section announced a substantial...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

Clark Hill PLC

DOJ's New FCPA Guidance and Pilot Program

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On April 5, 2016, in an effort to bolster FCPA Compliance, the Department of Justice issued its "Foreign Corrupt Practices Act Enforcement Plan and Guidance" identifying the following three steps to enhance its FCPA...more

Bracewell LLP

DOJ Launches FCPA Pilot Program to Promote Company Self-Reporting

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In a speech delivered last Wednesday by Assistant Attorney General Leslie Caldwell, the Justice Department’s (“DOJ”) Criminal Division announced the launch of a new Foreign Corrupt Practices Act (“FCPA”) “pilot program” that...more

Miller Canfield

DOJ’s Fraud Section Issues Foreign Corrupt Practices Act Enforcement Plan and Guidance

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On April 5, 2016, the Department of Justice’s Fraud Section (“DOJ”) issued its Foreign Corrupt Practices Act (“FCPA”) Enforcement Plan and Guidance (“Guidance”), which announced (1) a more than doubling of DOJ resources...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

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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

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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

Dorsey & Whitney LLP

DOJ Announces One-Year FCPA Enforcement Pilot Program

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The U.S. Department of Justice (“DOJ”) Criminal Division yesterday announced that its Fraud Section’s Foreign Corrupt Practices Act (“FCPA”) Unit is conducting a one-year FCPA enforcement pilot program (“Program”). A company...more

BCLP

DOJ’s “Half Off” Deals for Self-Reporting FCPA Misconduct: Certain Exclusions Apply, See Below for Details

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For the next year, the Justice Department may be offering up to a 50% discount on fines imposed in FCPA cases. Yesterday, the U.S. Department of Justice’s (“DOJ”) Criminal Division announced the launch of a one-year pilot...more

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