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Federal Sentencing Guidelines Criminal Penalties

Blank Rome LLP

A New Era in Federal Sentencing: Updates to the Guidelines and the Elimination of Departures

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The federal sentencing landscape in the United States could undergo a significant transformation with recent amendments to update the United States Sentencing Guidelines that will go into effect on November 1, 2025, unless...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

Courts Must Not “Reflexively Defer” To Sentencing Guidelines Commentary—Follow The Rule Of Lenity

Five more judges on the U.S. Court of Appeals for the Third Circuit agree with their colleague that courts must not “reflexively defer” to the U.S. Sentencing Guidelines commentary and should instead follow the rule of lenity...more

Dorsey & Whitney LLP

The Supreme Court - March 24, 2020

Dorsey & Whitney LLP on

Comcast Corp. v. National Assn. of African American-Owned Media, No. 18-1171: An African American-owned television-network operator, Entertainment Studios Network (“ESN”), unsuccessfully tried to have Comcast carry its...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

McDermott Will & Emery

DOJ Memorandum Clarifies US Sentencing Guidelines’ Fine Reduction Determination Process

McDermott Will & Emery on

The US Sentencing Guidelines permit reductions of criminal penalties based on a business organization’s inability to pay criminal fines, but were unclear about how it would make such determinations. An October 8 memorandum...more

Faegre Drinker Biddle & Reath LLP

DOJ Criminal Division Releases Criteria for Evaluating Companies’ Ability to Pay Fines

The criminal division of the U.S. Department of Justice formalized the criteria it will use to evaluate corporate defendants’ claims of inability to pay fines or monetary penalties. The memorandum, published October 8, 2019,...more

A&O Shearman

DOJ Introduces Guidance Over Inability-to-Pay Claims

A&O Shearman on

On October 8, 2019, the Department of Justice (“DOJ”) issued a memorandum (“Memorandum”) providing guidance on how the DOJ’s prosecutors will handle inability-to-pay claims from companies, intending to provide companies—and...more

Jackson Lewis P.C.

Department Of Justice Guidance On Companies’ Claim Of Inability To Pay Criminal Fines

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The Department of Justice Criminal Division has clarified its policy on the Department’s assessment of a company’s claim that it cannot afford to pay a criminal fine in a memorandum issued on October 8, 2019. Criminal...more

Jones Day

DOJ Announces Changes in White-Collar Criminal Enforcement in the Interest of Transparency

Jones Day on

The Situation: On October 8, 2019, the U.S. Department of Justice ("DOJ") announced two significant developments relating to the enforcement of white-collar crime: (i) new guidance on how prosecutors should evaluate requests...more

WilmerHale

DOJ Inability to Pay Guidance: Beyond Corporate Formalities

WilmerHale on

On October 8, 2019, the US Department of Justice (DOJ or Justice Department) issued new guidance on evaluating inability-to-pay arguments in a memorandum to the Criminal Division. The memorandum provides considerably more...more

Foley Hoag LLP - White Collar Law &...

DOJ Considers Guidance on Corporate Claims of Inability to Pay

On September 12, 2019, Deputy Assistant Attorney General Matthew Miner signaled that the Department of Justice may provide further guidance to prosecutors—and companies—on how to evaluate claims of corporate poverty. In a...more

Dorsey & Whitney LLP

The Supreme Court - June 4, 2018

Dorsey & Whitney LLP on

The Supreme Court of the United States issued five decisions today: Masterpiece Cakeshop, Ltd. v. Colorado Civil Rights Comm’n, No. 16-111: In 2012, a same-sex couple filed a complaint with the Colorado Civil Rights...more

Clark Hill PLC

DOJ's New FCPA Guidance and Pilot Program

Clark Hill PLC on

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

BakerHostetler

DOJ Attempts to Encourage Corporate Self-Disclosures With the Announcement of a One-Year FCPA Pilot Program

BakerHostetler on

Pursuing a classic “carrot and stick” approach to incentivizing corporate self-disclosure of FCPA violations and individual wrongdoing connected to FCPA violations, the Department of Justice (DOJ) Fraud Section announced a...more

Foley & Lardner LLP

The High Cost of an FCPA Violation

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Violations of the Foreign Corrupt Practices Act (“FCPA”) can lead to hefty penalties. Indeed, individuals who violate the FCPA, and their employers, could be on the hook for a variety of penalties described below. Companies...more

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