News & Analysis as of

Foreign Corrupt Practices Act (FCPA) Voluntary Disclosure Compliance

The Volkov Law Group

DOJ’s Balancing Act — Incentives to Cooperate and Deterrence (Part III of III)

The Volkov Law Group on

While DOJ did not have an overwhelming FCPA enforcement year, DOJ has devoted significant energy to tweaking its enforcement and compliance policies.  These measures were believed to coincide with a number of significant...more

The Volkov Law Group

The FCPA Year in Review — More of the Same with Some Twists (Part I of III)

The Volkov Law Group on

With the end of the Biden Administration, it is hard to identify a consistent theme relating to FCPA enforcement.  On the one hand, the Biden Administration talked a big game, elevating the anti-corruption fight as a national...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for December 2024

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

Bracewell LLP

Keeping an Eye on AI: DOJ Updates its Playbook for Corporate Compliance

Bracewell LLP on

On September 23, 2024, Principal Deputy Assistant Attorney General Nicole Argentieri announced that the US Department of Justice (DOJ) had issued updated guidance to federal prosecutors in its “Evaluation of Corporate...more

Adams & Reese

International Compliance Digest - September 2024

Adams & Reese on

New export controls, new section 301 duties, new OFAC requirements, new de minimis rule, new DOJ corporate compliance guidance, new international guidance on Russian sanctions. September had it all....more

American Conference Institute (ACI)

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more

The Volkov Law Group

DOJ Awards Declination to Proterial Cable America for Fraud — Proterial Pays $15.1 Million in Disgorgement

The Volkov Law Group on

DOJ is pushing hard for voluntary disclosures and urging companies to take advantage  of its Voluntary Disclosure Program.  The carrot is significant — a declination in exchange for cooperation, remediation and disgorgement....more

The Volkov Law Group

DOJ Issues New FCPA Declination: Boston Consulting Group Pays $14.4 Million

The Volkov Law Group on

The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination.  But even a declination comes with a requirement — the company has...more

Lathrop GPM

DOJ Criminal Division Announces Corporate Whistleblower Awards Pilot Program

Lathrop GPM on

In her remarks to the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco outlined the forthcoming whistleblower program that seeks to fill in the gaps of existing...more

Womble Bond Dickinson

DOJ Debuts Pilot Corporate Whistleblower Awards Program

Womble Bond Dickinson on

The U.S. Department of Justice’s (“DOJ”) Criminal Division announced its new Corporate Whistleblower Awards Pilot Program on August 1, 2024. The Pilot Program incentivizes whistleblowers to provide information to the DOJ so...more

Venable LLP

DOJ Criminal Division Launches New Corporate Whistleblower Award Program

Venable LLP on

On March 7, 2024, Deputy Attorney General Lisa Monaco announced the Department of Justice (DOJ) would release a new whistleblower rewards program for civil and criminal forfeitures. On August 1, 2024, DOJ did just that—as the...more

American Conference Institute (ACI)

The DOJ’s New Pilot Programs: A Bane for Compliance Programs

For years, Department of Justice officials have stressed how important chief compliance officers are as the first line of defense in fighting corporate crimes. While that’s true, compliance programs now have a competitor in...more

Thomas Fox - Compliance Evangelist

The FCPA Survival Guide

I am thrilled to announce my first podcast series based on a book I have written. The book and the podcast series are titled FCPA Survival Guide and Ethico sponsors. The book is available in the Kindle format, and you can...more

Thomas Fox - Compliance Evangelist

FCPA Survival Guide: Step 1 - Self-Disclosure

How can you survive an FCPA enforcement action? In this special podcast series, Tom Fox and Nick Gallo outline the Top 10 things you can do to reduce your overall fine and penalty, perhaps down to a complete declination. All...more

McCarter & English, LLP

DOJ Launches Pilot Program to Encourage Reporting of Criminal Activity

The Department of Justice (DOJ) has announced a pilot program to encourage potential whistleblowers to report criminal activity and cooperate with government investigations in exchange for substantial monetary payouts in the...more

Mintz

DOJ’s Criminal Division Announces Pilot Program on Voluntary Self-Disclosure for Individuals

Mintz on

Drawing on a carrot and stick approach, Department of Justice (“DOJ” or the “Department”) guidance in 2023 focused heavily on incentivizing companies to voluntarily self-disclose their misconduct. This guidance included the...more

Guidepost Solutions LLC

A “Quick Guide” to Government Whistleblower and Voluntary Self-Disclosure Programs: Heed the Warning from DOJ to Strengthen...

The Department of Justice (DOJ) has sounded the alarm: an aggressive crackdown on corporate misconduct is imminent. With an enforcement program on the horizon, corporations must heed the warning and take proactive measures to...more

The Volkov Law Group

Episode 316 -- DOJ Announces New Whistleblower Policy

The Volkov Law Group on

In a recent speech, on March 7, 2024, Deputy Attorney General Monaco announced that DOJ would be implementing in the next 90 days a new whistleblower program to reward reporting of criminal misconduct at both public and...more

The Volkov Law Group

Carrots and Sticks: DOJ’s Push to Incentivize Voluntary Disclosure of Corporate Misconduct (Part II of II)

The Volkov Law Group on

DOJ has been on a public relations campaign to push a simple message for corporations: if companies learn of misconduct, companies should disclose such misconduct to earn valuable benefits.  The quintessential question...more

Benesch

White Collar Quarterly Report | Q1 2024

Benesch on

We are thrilled to introduce the inaugural issue of our quarterly White Collar newsletter, a dedicated resource from Benesch’s White Collar, Government Investigations & Regulatory Compliance Practice Group. Each issue...more

Thomas Fox - Compliance Evangelist

Argentieri at ABA White Collar Conference: Corporate Enforcement, Part 1

There were recently two significant speeches by Department of Justice (DOJ) officials at the American Bar Association National Institute on White Collar Crime. The first was by Deputy Attorney General Lisa Monaco. The second...more

Goodwin

In Continuing Efforts to Incentivize Self-Disclosures and Cooperation, DOJ Announces Pilot Program to Pay Criminal Whistleblowers

Goodwin on

Over the last few years, the U.S. Department of Justice (“DOJ”) has continuously announced significant policies and programs directed at encouraging and rewarding the timely reporting of corporate wrongdoing, incentivizing...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

DOJ Official Cites Old West ‘WANTED’ Posters in Announcement of New Whistleblower Monetary Awards Program

On March 7, 2024, Deputy Attorney General Lisa Monaco said that the U.S. Department of Justice (DOJ) will test out a program to pay whistleblowers if they provide information on serious financial crimes and foreign and...more

American Conference Institute (ACI)

[Event] FCPA & Anti-Corruption for the Life Sciences Industry - May 9th - 10th, New York, NY

Hosted by the American Conference Institute, the 19th Annual FCPA & Anti-Corruption Conference for the Life Sciences Industry returns for another exciting year with carefully researched programming based on critical findings...more

Wiley Rein LLP

DOJ to Use ‘Carrots to Wield Larger Sticks’ in 2024

Wiley Rein LLP on

The more things change, the more things stay the same. For years, U.S. Department of Justice (DOJ) leadership has used the ABA National Institute on White Collar Crime and other major conferences to highlight enforcement...more

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