News & Analysis as of

Foreign Corrupt Practices Act (FCPA) Voluntary Disclosure Non-Prosecution Agreements

Fenwick & West LLP

DOJ Announces Key Revisions to Corporate Enforcement and Voluntary Self-Disclosure Policy

Fenwick & West LLP on

On May 12, 2025, the Head of the Department of Justice’s (DOJ) Criminal Division, Matthew Galeotti, announced a new white collar enforcement plan in a memorandum entitled “Focus, Fairness, and Efficiency in the Fight Against...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

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

Katten Muchin Rosenman LLP

Whistleblower Rewards Program Update: DOJ Explains and Expands Pilot Program for Voluntary Disclosures

On April 15, the Department of Justice (DOJ) publicly released a memorandum fleshing out its previously announced corporate whistleblower program, which is intended to induce individuals to report alleged criminal conduct,...more

Vinson & Elkins LLP

“Call Us Before We Call You”: SDNY Creates New Individual Self-Disclosure Program

Vinson & Elkins LLP on

On January 10, 2024, the United States Attorney’s Office for the Southern District of New York (“SDNY”) introduced the SDNY Whistleblower Pilot Program (“Pilot Program”), aimed at encouraging individuals to disclose...more

Eversheds Sutherland (US) LLP

SDNY announces new whistleblower program, continuing Justice’s push for self-disclosure

“Call us before we call you.” With this message, on January 10, 2024, the Southern District of New York announced the SDNY Whistleblower Pilot Program (Pilot Program), which seeks to encourage individual participants in...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for September 2023

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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

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 5-Lessons Learned

Over the past several blog posts, I have been exploring the Albemarle FCPA enforcement action.  We have explored in some detail the DOJ Non-Prosecution Agreement (NPA) and the SEC Administrative Order(Order). In this final...more

Morrison & Foerster LLP

Deputy Attorney General Lisa Monaco Announces Changes to DOJ’s Corporate Criminal Enforcement Policies

On September 15, 2022, the U.S. Department of Justice (DOJ)’s Deputy Attorney General Lisa Monaco announced new guidance and policies regulating corporate criminal enforcement. The new policies emphasize that DOJ will not...more

Jones Day

DOJ Policy Increases Incentives for Self-Reporting of Potentially Willful Trade Violations

Jones Day on

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

WilmerHale

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

WilmerHale on

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

Thomas Fox - Compliance Evangelist

General Cable FCPA Enforcement Action – Part II: The Comeback

Yesterday I began an exploration of the General Cable Corporation (General Cable) Foreign Corrupt Practices Act (FCPA) enforcement action. It was settled with the DOJ via a Non-Prosecution Agreement (NPA) and the SEC via a...more

K&L Gates LLP

The First Ninety Days of the FCPA Unit’s Pilot Program

K&L Gates LLP on

On April 5, 2016, the Department of Justice (“DOJ”) introduced a yearlong “Pilot Program” to guide the conduct of investigations and prosecutions pursuant to the Foreign Corrupt Practices Act (“FCPA”). Announced by Assistant...more

The Volkov Law Group

Analogic FCPA Settlement – From Russia With(out) Love

The Volkov Law Group on

BK Medical, a subsidiary of the Denmark company, Analogic settled an FCPA enforcement action last week with the Justice Department and the SEC for approximately $14 million. Analogic agreed to pay $3.4 million to the Justice...more

The Volkov Law Group

Akamai and Nortek – DOJ Touts Declinations Under FCPA Pilot Program

The Volkov Law Group on

DOJ’s FCPA Unit knows what they are doing. In the immediate weeks after the release of the FCPA Pilot Program, DOJ publicly released two declination letters for Akamai Technologies and Nortek, Inc. and the SEC announced...more

Thomas Fox - Compliance Evangelist

How to garner a NPA and Declination: Akamai and Nortek – Part II

Yesterday, I began a three-part series on how two companies, which came to Foreign Corrupt Practices Act (FCPA) grief in China for bribery within their Chinese business units, received the rather stunning results of both Non...more

Bracewell LLP

DOJ Announces First Declinations After Implementing FCPA Pilot Program

Bracewell LLP on

The U.S. Department of Justice (DOJ) issued its first set of public declinations since its April unveiling of a new self-reporting Foreign Corrupt Practices Act (FCPA) pilot program. On June 7, 2016, Akamai Technologies,...more

Thomas Fox - Compliance Evangelist

How to garner a NPA and Declination: Akamai and Nortek – Part I

It certainly did not take long for companies to see the benefit of the Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) Pilot Program around FCPA enforcement as this week there where two public declinations...more

Morgan Lewis

SEC Policy Change: Voluntary Disclosure Now Required for DPA/NPA Resolutions in FCPA Cases

Morgan Lewis on

New SEC policy requires companies to self-report FCPA violations in order to be eligible for deferred prosecution agreements and non-prosecution agreements....more

The Volkov Law Group

IAP Worldwide FCPA Settlement: The Power of “Voluntary” Disclosure

The Volkov Law Group on

Okay, everyone take out their tea leaves and let’s get started on the IAP corruption case – DOJ announced a Non-Prosecution Agreement with IAP Worldwide Services and the criminal plea of a former executive who funneled bribes...more

The Volkov Law Group

Playing With Ralph Lauren: A Fair Settlement?

The Volkov Law Group on

The FCPA Paparazzi has been at it again – it is fascinating to watch the reaction of practitioners and commentators in the FCPA arena. ...more

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